The Resource A critical look at the earnings stripping regulations

A critical look at the earnings stripping regulations

Label
A critical look at the earnings stripping regulations
Title
A critical look at the earnings stripping regulations
Creator
Subject
Summary
The IRS was authorized to regulate earnings stripping on interest paid to foreign owners by the Omnibus Budget Reconciliation Act of 1989. IRC 163(j) was enacted to serve this purpose, but has been criticized for the additional complexity it would incur and the possibility of discriminatory taxation of foreign corporations in violation of bilateral tax treaties. In addition, the rule establishes a 1.5 to 1 debt to equity standard for determining deductibility of interest expense which has also been questioned
Citation source
In: International tax journal. - New York. - Vol. 18 (1992),
http://library.link/vocab/creatorName
  • McClintock, M
  • Royse, R
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • earnings stripping
  • deductions
  • foreign company
Label
A critical look at the earnings stripping regulations
Instantiates
Publication
Label
A critical look at the earnings stripping regulations
Publication

Library Locations

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