The Resource Domestic reverse hybrids : Treasury seeks to tighten DCL rules

Domestic reverse hybrids : Treasury seeks to tighten DCL rules

Label
Domestic reverse hybrids : Treasury seeks to tighten DCL rules
Title
Domestic reverse hybrids : Treasury seeks to tighten DCL rules
Creator
Subject
Language
eng
Summary
This article addresses the regulations related to dual consolidated losses (DCL) incurred by dual resident corporations. Back in 2007 when the IRS and Treasury issued final regulations, Treasury addressed the issue in the preamble of the 2007 final regulations of whether the DCL rules under section 1503(d) should be applied to certain structures involving domestic reverse hybrids. There is an ever increasing scrutiny on structures involving hybridity and what government authorities perceive as inappropriate tax consequences resulting from hybridity. Given this focus on hybridity, as discussed more fully in this article, it is not surprising that Treasury would revisit the issue relating to domestic reverse hybrids in the context of the application of the DCL rules
Citation source
In: Journal of international taxation. - New York. - Vol. 30 (2019), no. 8 ; p. 42-47; 64
http://library.link/vocab/creatorName
Calianno, J.M
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • double dipping
  • dual consolidated loss
  • dual residence
  • hybrid entity
Label
Domestic reverse hybrids : Treasury seeks to tighten DCL rules
Instantiates
Publication
Label
Domestic reverse hybrids : Treasury seeks to tighten DCL rules
Publication

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