The Resource Claims Court and IRS : redetermined foreign taxes relate back to year incurred, which may be "pre-1987"

Claims Court and IRS : redetermined foreign taxes relate back to year incurred, which may be "pre-1987"

Label
Claims Court and IRS : redetermined foreign taxes relate back to year incurred, which may be "pre-1987"
Title
Claims Court and IRS : redetermined foreign taxes relate back to year incurred, which may be "pre-1987"
Creator
Subject
Language
eng
Summary
Taxpayers that acquire foreign companies potentially subject to future foreign tax controversies may want to consider whether it is possible to move the acquired companies' profits and taxes out of their default "pre-1987" layers and into post-1986 pools somewhere in the foreign structure
Citation source
In: Journal of international taxation. - New York. - Vol. 26 (2015),
http://library.link/vocab/creatorName
Fischl, A.
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • acquisition
  • foreign company
  • foreign tax credit
  • case law
Label
Claims Court and IRS : redetermined foreign taxes relate back to year incurred, which may be "pre-1987"
Instantiates
Publication
Label
Claims Court and IRS : redetermined foreign taxes relate back to year incurred, which may be "pre-1987"
Publication

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