The Resource Inherently hedgeable : hedging foreign currency exposure arising from the branch operations of a CFC

Inherently hedgeable : hedging foreign currency exposure arising from the branch operations of a CFC

Label
Inherently hedgeable : hedging foreign currency exposure arising from the branch operations of a CFC
Title
Inherently hedgeable : hedging foreign currency exposure arising from the branch operations of a CFC
Creator
Subject
Language
eng
Summary
Many challenging issues arise in interpreting and applying the subpart F rules governing foreign currency gains and losses. One major issue, which has increasingly arisen in IRS audits, involves the application of the 'business needs exception' of Reg. Par. 1.954-2(g)(2)(ii) in the context of a CFC that operates through multiple branches or qualified business units (QBUs) using different functional currencies. This article discusses whether certain hedges can qualify for the business needs exception
Citation source
In: International tax journal. - Chicago. - Vol. 37 (2011), no. 5 (September-October) ; p. 11-18
http://library.link/vocab/creatorName
  • Harter, L.G
  • Lee, R
  • Shapiro, D.H
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • foreign currency gains and losses
  • hedging transaction
  • CFC
  • Subpart F income
  • disregarded entity
Label
Inherently hedgeable : hedging foreign currency exposure arising from the branch operations of a CFC
Instantiates
Publication
Label
Inherently hedgeable : hedging foreign currency exposure arising from the branch operations of a CFC
Publication

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