The Resource Notice 2015-79 : strewing foreign tax in the path of inversions

Notice 2015-79 : strewing foreign tax in the path of inversions

Label
Notice 2015-79 : strewing foreign tax in the path of inversions
Title
Notice 2015-79 : strewing foreign tax in the path of inversions
Creator
Subject
Language
eng
Summary
The principal effect of Notice 201579 seems likely to be an increase in tax paid to foreign jurisdictions. The IRS and Treasury appear to hope that the prospect of paying more foreign tax will dissuade U.S. companies from undertaking these transactions. Given that the U.S. corporate tax rate remains considerably higher than that of most other countries, however, U.S. companies may consider some additional foreign tax to be a price worth paying
Citation source
In: Tax management international journal. - Arlington. - Vol. 45 (2016),
http://library.link/vocab/creatorName
Dubert, C
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • inversion transaction
  • anti-avoidance
  • Subpart F income
  • CFC
Label
Notice 2015-79 : strewing foreign tax in the path of inversions
Instantiates
Publication
Label
Notice 2015-79 : strewing foreign tax in the path of inversions
Publication

Library Locations

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