The Resource AM 2015-002: the IRS reinterprets the tax rate disparity test

AM 2015-002: the IRS reinterprets the tax rate disparity test

Label
AM 2015-002: the IRS reinterprets the tax rate disparity test
Title
AM 2015-002: the IRS reinterprets the tax rate disparity test
Creator
Subject
Language
eng
Summary
US multinationals that sell products through controlled foreign corporations (CFC) are subject to several provisions of the Subpart F rules, which determine whether the CFCs' earnings must be included in their US shareholder's income currently. Many CFCs operate through branches or disregarded (or "checked") entities to allow for tax-efficient movement of cash among group members. However, such structures also require consideration of the "branch rule" of the foreign base company sales income provisions. In a generic legal advice memorandum, AM 2015-002, the IRS has provided the most detailed guidance to date regarding the application of the tax rate disparity test. On this question of mechanics, the IRS has made a significant step in attempting to bring further clarity by providing a new computational method for applying aspects of the tax rate disparity test. AM 2015-002 introduces a new methodology for performing the tax rate disparity test and provides taxpayers with a step-by-step guide for following it
Citation source
In: International tax journal. - Chicago. - Vol. 41 (2015),
http://library.link/vocab/creatorName
  • Chen, M.M
  • Markham, C.S
  • Gibson, M.J
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • CFC
  • Subpart F income
  • branch rule
  • foreign base company income
  • accounting
  • losses
Label
AM 2015-002: the IRS reinterprets the tax rate disparity test
Instantiates
Publication
Label
AM 2015-002: the IRS reinterprets the tax rate disparity test
Publication

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