The Resource Tax Court rulings on sale of franchise, source of stock loss for US foreign tax credit purposes

Tax Court rulings on sale of franchise, source of stock loss for US foreign tax credit purposes

Label
Tax Court rulings on sale of franchise, source of stock loss for US foreign tax credit purposes
Title
Tax Court rulings on sale of franchise, source of stock loss for US foreign tax credit purposes
Creator
Subject
Summary
Decisions of 29 January 1997 and 18 June 1997 of the US Tax Court. The author examines the US Tax Court's decisions in International Multifoods Corporation and Affiliated Companies v. Commissioner of Internal Revenue. The issues discussed include the proper tax treatment of the disposition of a franchise by a US company and whether the loss suffered upon a disposition of stock held in a foreign subsidiary is properly treated as a US source loss for purposes of calculating the US foreign tax credit limitation
Citation source
In: Bulletin for international fiscal documentation. - Amsterdam. - Vol. 52 (1998),
http://library.link/vocab/creatorName
McCarthy, C.M
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • franchise
  • losses
  • foreign tax credit
Label
Tax Court rulings on sale of franchise, source of stock loss for US foreign tax credit purposes
Instantiates
Publication
Label
Tax Court rulings on sale of franchise, source of stock loss for US foreign tax credit purposes
Publication

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      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.3736660 4.9336932
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