The Resource Branch rule update: two IRS private letter rulings offer guidance on the effective rate of tax test

Branch rule update: two IRS private letter rulings offer guidance on the effective rate of tax test

Label
Branch rule update: two IRS private letter rulings offer guidance on the effective rate of tax test
Title
Branch rule update: two IRS private letter rulings offer guidance on the effective rate of tax test
Creator
Subject
Language
eng
Summary
On 29 December 2008, the IRS and the Treasury Department issued temporary regulations updating and modifying the branch rule regulations under Reg. Par. 1.954-3(b). These Temporary Regulations continue to employ a "tax rate disparity test" to determine whether a branch has substantially the same effect as a wholly owned subsidiary. The authors discuss developments in the area, which are important for US based companies employing international check-the-box structures
Citation source
In: International tax journal. - Chicago. - Vol. 36 (2010),
http://library.link/vocab/creatorName
  • Fuller, J.P
  • Halpern, A.S
  • Fitzgibbon, T.J
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • branch rule
  • private ruling
Label
Branch rule update: two IRS private letter rulings offer guidance on the effective rate of tax test
Instantiates
Publication
Label
Branch rule update: two IRS private letter rulings offer guidance on the effective rate of tax test
Publication

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