The Resource Foreign tax credit splitter rules : impact on private equity investments

Foreign tax credit splitter rules : impact on private equity investments

Label
Foreign tax credit splitter rules : impact on private equity investments
Title
Foreign tax credit splitter rules : impact on private equity investments
Creator
Subject
Language
eng
Summary
This article discusses the impact of Section 909 on private equity funds, one of the many types of cross-border investors, and the key Section 909 issues that these funds must consider within the broader context of the U.S. federal income taxation of cross-border transactions. The issues addressed in this article include the impact of Section 909 on hybrid financing instruments, partnership interbranch payment structures, and reverse hybrid investment structures. The article also highlights some of the primary Section 909 issues, from a private equity investment perspective, on which guidance from Treasury and the IRS is critical
Citation source
In: Journal of international taxation. - New York. - Vol. 23 (2012),
http://library.link/vocab/creatorName
  • Arora, P
  • Kalungi, R
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • foreign tax credit
  • private equity
  • cross-border transaction
  • hybrid financing
  • hybrid entity
Label
Foreign tax credit splitter rules : impact on private equity investments
Instantiates
Publication
Label
Foreign tax credit splitter rules : impact on private equity investments
Publication

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