The Resource Subpart F and basket look-through for partnerships : a clash of aggregate and entity treatments

Subpart F and basket look-through for partnerships : a clash of aggregate and entity treatments

Label
Subpart F and basket look-through for partnerships : a clash of aggregate and entity treatments
Title
Subpart F and basket look-through for partnerships : a clash of aggregate and entity treatments
Creator
Subject
Language
eng
Summary
When interest is paid to a CFC by a partnership that is owned by one or more related CFC partners, the Sec. 904 regulations apply an entity approach to partnerships, whereas Notice 2007-9, which provides Sec. 954(c)(6) guidance, takes an aggregate approach. This article explores the anomalies and uncertainties that arise as a result of this disparate treatment of partnerships. The first section describes the general allocation and apportionment rules applicable to interest accrued by a CFC, the second section provides the interest income characterization rules for purposes of Sec. 904(d)(3) and Sec. 954(c)(6), the third section describes the special partnership rules applicable to the two look-through regimes, and the fourth section provides six examples illustrating results and issues that arise due to the look-through treatment of partnerships
Citation source
In: Tax management international journal. - Arlington. - Vol. 43 (2014),
Geographic coverage
North America
Language note
English
Label
Subpart F and basket look-through for partnerships : a clash of aggregate and entity treatments
Instantiates
Publication
Label
Subpart F and basket look-through for partnerships : a clash of aggregate and entity treatments
Publication

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