The Resource 10/50 look-through rules : through the CFC look-through looking glass

10/50 look-through rules : through the CFC look-through looking glass

Label
10/50 look-through rules : through the CFC look-through looking glass
Title
10/50 look-through rules : through the CFC look-through looking glass
Creator
Subject
Language
  • eng
  • eng
Summary
This article examines the mechanics and scope of the American Jobs Creation Act of 2004 look-through regime for 10/50 companies, compares the regime to CFC look-through, explores the new "substantiation" exception both in the context of the pre-2007 multiple-basket regime as well as the post-2006 two-basket regime, and discusses the effects of the new regime on interest expense apportionment, overall foreign loss and separate limitation loss accounts, and foreign tax credit carryovers and carrybacks
Citation source
In: Tax management international journal. - Vol. 34 (2005),
http://library.link/vocab/creatorName
  • Goldstein, S
  • Halpern, I
  • Kearney, T
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • CFC
  • looking through
  • foreign tax credit
Label
10/50 look-through rules : through the CFC look-through looking glass
Link
https://library.ibfd.org/custom/web/SD_PDF/scans/2005/T/TAXMAINJ/vol.34/2_83-96.zip
Publication
Note
20050311

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.3736660 4.9336932
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