The Resource Outbound stock transfers. A commentary on the proposed Section 367(a) regulations

Outbound stock transfers. A commentary on the proposed Section 367(a) regulations

Label
Outbound stock transfers. A commentary on the proposed Section 367(a) regulations
Title
Outbound stock transfers. A commentary on the proposed Section 367(a) regulations
Creator
Subject
Summary
This article discusses the outbound stock transfer rules in the proposed section 367(a) regulations, how the rules differ from prior rules, and the principles that underlie them. The author suggests changes in the proposed regulations where the regulations appear to lack a theoretical rationale or appear to restrict unnecessarily the ability of US based multinationals to face competitive challenges and to take advantage of business opportunities in situations where the potential that a transfer is tax motivated is relatively small
Citation source
In: Tax Notes International. - Arlington. - Vol. 5 (1992),
http://library.link/vocab/creatorName
Elliot, Richard M
Language note
English
http://library.link/vocab/subjectName
  • outbound transaction
  • capital gains tax
  • stock exchange
  • reorganization
Label
Outbound stock transfers. A commentary on the proposed Section 367(a) regulations
Instantiates
Publication
Abbreviated title
TaxNint
Label
Outbound stock transfers. A commentary on the proposed Section 367(a) regulations
Publication
Abbreviated title
TaxNint

Library Locations

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