The Resource A decade of shooting itself in the foot : the IRS's battle against the Killer B

A decade of shooting itself in the foot : the IRS's battle against the Killer B

Label
A decade of shooting itself in the foot : the IRS's battle against the Killer B
Title
A decade of shooting itself in the foot : the IRS's battle against the Killer B
Creator
Subject
Language
eng
Summary
The U.S. IRS recently unleashed its sixth, and perhaps final, weapon in its ongoing battle against the "Killer B" with the issuance of Notice 2016-73 (the 2016 Notice). The IRS first declared war on the transactions in 2006 when it issued Notice 2006-85 and has spent that past decade in a pitched battle with taxpayers to stop the practice, suffering largely self-inflicted wounds. While the IRS attacked the form of the Killer B transaction generally, the transaction in fact comes in two distinct species, the "basic" Killer B and the "internal" Killer B, each of which is described int his article. Even though the basic Killer B did not present the same kind of planning opportunities that the internal Killer B did, the IRS refused to distinguish between these two species of Killer B transactions, leading the IRS to fight the wrong enemy and opening the door to variations on the transactions that the IRS had intended to stop. As a result, the IRS spent the past decade drafting ever more complex rules to stop the Killer B transactions. While the IRS may finally declare victory with its issuance of the 2016 Notice, which appears to have stopped the latest round of Killer B transactions that have so concerned the IRS, the IRS may want to re-think its approach to stopping Killer B transactions in general before issuing the temporary and proposed regulations described in the 2016 Notice
Citation source
In: International tax journal. - Riverwoods. - Vol. 43 (2017), no. 3 (May-June) ; p. 5-14
http://library.link/vocab/creatorName
Stevenson, R.C
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • triangular reorganization
  • repatriation
  • CFC
Label
A decade of shooting itself in the foot : the IRS's battle against the Killer B
Instantiates
Publication
Label
A decade of shooting itself in the foot : the IRS's battle against the Killer B
Publication

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