The Resource Favorable IRS guidance on tax benefits for U.S. possessions software business models

Favorable IRS guidance on tax benefits for U.S. possessions software business models

Label
Favorable IRS guidance on tax benefits for U.S. possessions software business models
Title
Favorable IRS guidance on tax benefits for U.S. possessions software business models
Creator
Subject
Language
eng
Summary
On 18 September 2006 the IRS published favourable guidance for software and other e-commerce companies looking to establish operations in U.S. possessions that have low-tax regimes. IRS notice 2006-76, 2006-38 IRB 459 provides two common e-commerce business models as positive examples that will satisfy the requirements of new Section 937(b), which could otherwise limit tax benefits. The guidance should have an immediate impact on the attractiveness of U.S. possessions, such as the U.S. Virgin Islands, that have an active tax concession regime. Based on various economic factors, a concession of up to 90% of the regular possession corporate income tax rate is possible. The result could be a corporate tax rate of approximately 4%, rivaling those of Ireland, Singapore and the Caribbean
Citation source
In: Journal of international taxation. - New York. - Vol. 17 (2006),
http://library.link/vocab/creatorName
Ryan, E.D
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • corporate income tax
  • e-commerce
  • tax holiday
  • concession
Label
Favorable IRS guidance on tax benefits for U.S. possessions software business models
Instantiates
Publication
Label
Favorable IRS guidance on tax benefits for U.S. possessions software business models
Publication

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