The Resource Outbound transfers of domestic partnership interests - a Code Sec. 367(a) / 367(b) dichotomy?

Outbound transfers of domestic partnership interests - a Code Sec. 367(a) / 367(b) dichotomy?

Label
Outbound transfers of domestic partnership interests - a Code Sec. 367(a) / 367(b) dichotomy?
Title
Outbound transfers of domestic partnership interests - a Code Sec. 367(a) / 367(b) dichotomy?
Creator
Subject
Language
eng
Summary
Applying the subchapter K provisions to international tax transactional analysis has long proved a vexing challenge for tax practitioners. This difficulty often occurs due to the fact that the subchapter K provisions at times mandate an aggregate approach and at other times an entity approach - in each case, with significant collateral consequences to the international tax analysis. This article describes a fact pattern in which it appears that the applicable rules apply an aggregate approach for purposes of Code Sec. 367(a) but an entity approach for purposes of Code Sec. 367(b). The autors discuss the technical rationale behind this dichotomy and question the policy issues that the dichotomy raises
Citation source
In: International tax journal. - Chicago. - Vol. 37 (2011), no. 5 (September-October) ; p. 19-22, 62-64
Language note
English
Label
Outbound transfers of domestic partnership interests - a Code Sec. 367(a) / 367(b) dichotomy?
Instantiates
Publication
Label
Outbound transfers of domestic partnership interests - a Code Sec. 367(a) / 367(b) dichotomy?
Publication

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