The Resource New TIPRA CFC look-through rule : time to begin tailored tax planning - one size does not fit all

New TIPRA CFC look-through rule : time to begin tailored tax planning - one size does not fit all

Label
New TIPRA CFC look-through rule : time to begin tailored tax planning - one size does not fit all
Title
New TIPRA CFC look-through rule : time to begin tailored tax planning - one size does not fit all
Creator
Subject
Language
eng
Summary
The Tax Increase Prevention and Reconciliation Act of 2005 (TIPRA) (P.L. 109-222, section 103(b)(1)) has codified as Section 954(c)(6) a new "look-through" rule for the treatment of certain payments between related controlled foreign corporations to the extent that those payments are not attributable to Subpart F income. This article discusses the new rule
Citation source
In: Journal of international taxation. - New York. - Vol. 17 (2006),
http://library.link/vocab/creatorName
  • Ocasal, C
  • Lubkin, G
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • CFC
  • looking through
  • Subpart F income
Label
New TIPRA CFC look-through rule : time to begin tailored tax planning - one size does not fit all
Instantiates
Publication
Label
New TIPRA CFC look-through rule : time to begin tailored tax planning - one size does not fit all
Publication

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.3736660 4.9336932
Processing Feedback ...