The Resource PLR 200952031: dividends received deduction in the cross-border context

PLR 200952031: dividends received deduction in the cross-border context

Label
PLR 200952031: dividends received deduction in the cross-border context
Title
PLR 200952031: dividends received deduction in the cross-border context
Creator
Subject
Language
eng
Summary
In 2009, the IRS issued private letter ruling (PLR) 200952031, which addressed a number of questions related to the transfer of earnings and profits from a domestic corporation to a foreign corporation in a reorganization, and to the treatment of distributions of earnings and profits generated after the transaction. In this article, the authors examine the many questions that were answered in the PLR, identify questions that were left unanswered, and discuss other interesting fact patterns that might implicate the rulings given in the PLR
Citation source
In: Tax management international journal. - Arlington. - Vol. 39 (2010),
http://library.link/vocab/creatorName
  • Collins, M
  • Estrada, M
  • Pendarvis, C
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • ruling
  • reorganization
  • dividends received deduction
  • CFC
  • Subpart F income
Label
PLR 200952031: dividends received deduction in the cross-border context
Instantiates
Publication
Label
PLR 200952031: dividends received deduction in the cross-border context
Publication

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