The Resource The application of the branch rule to partnerships

The application of the branch rule to partnerships

Label
The application of the branch rule to partnerships
Title
The application of the branch rule to partnerships
Creator
Subject
Language
eng
Summary
Follow-up to an article by Edward C. Osterberg, Jr. discussing Private Letter Ruling 201002024 (Jan. 15, 2010) in which the IRS applied the branch rule "tax rate disparity test" and ruled that a CFC's distributive share of income from a foreign partnership, attributable to the activities of disregarded entities owned by the partnership, would not constitute foreign base company sales income. This article expands on Osterberg's analysis and seeks to provide some additional insights, including how the final result in the ruling is consistent with the temporary branch rule regulations
Citation source
In: International tax journal. - Chicago. - Vol. 36 (2010),
http://library.link/vocab/creatorName
Neumann, L.B
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • CFC
  • partnership
  • branch rule
  • private ruling
Label
The application of the branch rule to partnerships
Instantiates
Publication
Label
The application of the branch rule to partnerships
Publication

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.3736660 4.9336932
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