The Resource Avoiding double taxation of previously taxed income in multinational restructurings

Avoiding double taxation of previously taxed income in multinational restructurings

Label
Avoiding double taxation of previously taxed income in multinational restructurings
Title
Avoiding double taxation of previously taxed income in multinational restructurings
Creator
Subject
Summary
This article overviews the advance ruling issued by the IRS that clarifies to some degree measures that can be taken to avoid a double inclusion of previously taxed income when Internal Revenue Code section 304 applies in a cross-chain sale. The author explains that the interplay of code provisions like 959(d) and 304 having different objectives can lead to traps
Citation source
In: Tax Notes International. - Arlington. - (1992),
http://library.link/vocab/creatorName
Hoke, William
Language note
English
http://library.link/vocab/subjectName
  • CFC
  • reorganization
Label
Avoiding double taxation of previously taxed income in multinational restructurings
Instantiates
Publication
Abbreviated title
TaxNint
Label
Avoiding double taxation of previously taxed income in multinational restructurings
Publication
Abbreviated title
TaxNint

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.37366609999999 4.9336932
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