The Resource Tax court upholds hybrid arrangement : NA General Partnership & Subsidiaries and the strange history of the double dip

Tax court upholds hybrid arrangement : NA General Partnership & Subsidiaries and the strange history of the double dip

Label
Tax court upholds hybrid arrangement : NA General Partnership & Subsidiaries and the strange history of the double dip
Title
Tax court upholds hybrid arrangement : NA General Partnership & Subsidiaries and the strange history of the double dip
Creator
Subject
Language
eng
Summary
This article reviews the technical issues presented by the NA General Partnership & Subsidiaries case. This case highlights the ongoing tension in the debate over international tax "arbitrage". In particular, the case illustrates the difficulties posed by a system without clearly defined policies or guidelines for distinguishing between appropriate and inappropriate "double dip" planning. The law has evolved into a set of hypertechnical and narrowly crafted anti-abuse rules that taxpayers can frequently avoid and increasingly aggressive (but sometimes inconsistent) recent efforts by the IRS to challenge certain hybrid instruments and structures through common law doctrines
Citation source
In: International tax journal. - Chicago. - Vol. 38 (2012),
http://library.link/vocab/creatorName
  • Wilder, M.J
  • Feldgarden, R
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • double dipping
  • hybrid entity
  • tax arbitrage
  • case law
Label
Tax court upholds hybrid arrangement : NA General Partnership & Subsidiaries and the strange history of the double dip
Instantiates
Publication
Label
Tax court upholds hybrid arrangement : NA General Partnership & Subsidiaries and the strange history of the double dip
Publication

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