The Resource New Code Sec. 267A : the United States joins the anti-hybrid mix

New Code Sec. 267A : the United States joins the anti-hybrid mix

Label
New Code Sec. 267A : the United States joins the anti-hybrid mix
Title
New Code Sec. 267A : the United States joins the anti-hybrid mix
Creator
Subject
Language
eng
Summary
On 22 December 2017, President Trump signed the 2017 Tax Reform Reconciliation Act (also known as the Tax Cuts and Jobs Act, the TCJA). The TCJA makes significant changes to the U.S. international tax rules. Many of these newly enacted changes relate to the transition from a worldwide tax system to a so-called "territorial" tax system, including a dividend-received deduction for foreign source dividends. The TCJA also contains various anti-deferral and anti-abuse provisions, intended to protect the U.S. tax base in a territorial construct. This article reviews and addresses the impact of one of these newly enacted provisions found in Code Sec. 267A, which is among the United States' first statutory attempts in combating hybrid mismatch arrangements and similar payments
Citation source
In: International tax journal. - Riverwoods. - Vol. 44 (2018), no. 2 (March-April) ; p. 5-8
http://library.link/vocab/creatorName
  • McHoney, D.L
  • Ramstetter, P. (Jr.)
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • tax reform
  • tax system
  • hybrid mismatch
  • dividends received deduction
  • TCJA
  • BEPS Project (OECD)
Label
New Code Sec. 267A : the United States joins the anti-hybrid mix
Instantiates
Publication
Label
New Code Sec. 267A : the United States joins the anti-hybrid mix
Publication

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