The Resource Another attack on perceived repatriations - the IRS issues temporary regulations under Par. 956

Another attack on perceived repatriations - the IRS issues temporary regulations under Par. 956

Label
Another attack on perceived repatriations - the IRS issues temporary regulations under Par. 956
Title
Another attack on perceived repatriations - the IRS issues temporary regulations under Par. 956
Creator
Subject
Language
  • eng
  • eng
Summary
This article provides (a) a discussion of the typical transaction that has resulted in the temporary regulations along with a discussion of some of the subchapter C rules that are central to the analysis, (b) an overview of Par. 956, (c) the authority relied on by the IRS to curb this perceived abuse, and (d) the temporary regulation under Par. 956 along with examples illustrating its application
Citation source
In: Tax management international journal. - Arlington. - Vol. 37 (2008),
http://library.link/vocab/creatorName
  • Calianno, J.M
  • Spitzenberger, J.M
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • CFC
  • repatriation
Label
Another attack on perceived repatriations - the IRS issues temporary regulations under Par. 956
Link
https://library.ibfd.org/custom/web/SD_PDF/scans/2008/T/TAXMAINJ/vol.37/12_732-738.zip
Publication
Note
20090107

Library Locations

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      52.3736660 4.9336932
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