The Resource The non-domiciled alien whose RPHC has no treaty protection : coping with the anti-inversion rules of par. 7874
The non-domiciled alien whose RPHC has no treaty protection : coping with the anti-inversion rules of par. 7874
Resource Information
The item The non-domiciled alien whose RPHC has no treaty protection : coping with the anti-inversion rules of par. 7874 represents a specific, individual, material embodiment of a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation.This item is available to borrow from 1 library branch.
Resource Information
The item The non-domiciled alien whose RPHC has no treaty protection : coping with the anti-inversion rules of par. 7874 represents a specific, individual, material embodiment of a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation.
This item is available to borrow from 1 library branch.
- Summary
- When the anti-inversion rules of par. 7874 were enacted in 2004, they were generally intended to prevent U.S.-based multinationals with predominantly U.S. shareholders from "expatriating" in order to achieve prospectively various kinds of U.S. corporate income tax savings. The rules were not drafted so as to apply only to U.S.-owned U.S. companies, however, with the result that they can apply equally to U.S. companies that have always been foreign-owned. The rules can apply, moreover, even though the expatriation of a foreign-owned U.S. company - if it were able to avoid par. 7874 - would be unlikely to achieve any U.S. income tax saving, but only a U.S. estate tax saving
- Language
- eng
- Label
- The non-domiciled alien whose RPHC has no treaty protection : coping with the anti-inversion rules of par. 7874
- Title
- The non-domiciled alien whose RPHC has no treaty protection : coping with the anti-inversion rules of par. 7874
- Language
- eng
- Summary
- When the anti-inversion rules of par. 7874 were enacted in 2004, they were generally intended to prevent U.S.-based multinationals with predominantly U.S. shareholders from "expatriating" in order to achieve prospectively various kinds of U.S. corporate income tax savings. The rules were not drafted so as to apply only to U.S.-owned U.S. companies, however, with the result that they can apply equally to U.S. companies that have always been foreign-owned. The rules can apply, moreover, even though the expatriation of a foreign-owned U.S. company - if it were able to avoid par. 7874 - would be unlikely to achieve any U.S. income tax saving, but only a U.S. estate tax saving
- Citation source
- In: Tax management international journal. - Arlington. - Vol. 43 (2014),
- http://library.link/vocab/creatorName
- Bissell, T.S
- Geographic coverage
- North America
- Language note
- English
- http://library.link/vocab/subjectName
-
- anti-inversion
- immovable property
- holding company
- treaty benefits
- inheritance tax
- Label
- The non-domiciled alien whose RPHC has no treaty protection : coping with the anti-inversion rules of par. 7874
- Label
- The non-domiciled alien whose RPHC has no treaty protection : coping with the anti-inversion rules of par. 7874
Embed
Settings
Select options that apply then copy and paste the RDF/HTML data fragment to include in your application
Embed this data in a secure (HTTPS) page:
Layout options:
Include data citation:
<div class="citation" vocab="http://schema.org/"><i class="fa fa-external-link-square fa-fw"></i> Data from <span resource="http://link.library.ibfd.org/portal/The-non-domiciled-alien-whose-RPHC-has-no-treaty/rDqndueunhc/" typeof="Book http://bibfra.me/vocab/lite/Item"><span property="name http://bibfra.me/vocab/lite/label"><a href="http://link.library.ibfd.org/portal/The-non-domiciled-alien-whose-RPHC-has-no-treaty/rDqndueunhc/">The non-domiciled alien whose RPHC has no treaty protection : coping with the anti-inversion rules of par. 7874</a></span> - <span property="potentialAction" typeOf="OrganizeAction"><span property="agent" typeof="LibrarySystem http://library.link/vocab/LibrarySystem" resource="http://link.library.ibfd.org/"><span property="name http://bibfra.me/vocab/lite/label"><a property="url" href="http://link.library.ibfd.org/">International Bureau of Fiscal Documentation</a></span></span></span></span></div>
Note: Adjust the width and height settings defined in the RDF/HTML code fragment to best match your requirements
Preview
Cite Data - Experimental
Data Citation of the Item The non-domiciled alien whose RPHC has no treaty protection : coping with the anti-inversion rules of par. 7874
Copy and paste the following RDF/HTML data fragment to cite this resource
<div class="citation" vocab="http://schema.org/"><i class="fa fa-external-link-square fa-fw"></i> Data from <span resource="http://link.library.ibfd.org/portal/The-non-domiciled-alien-whose-RPHC-has-no-treaty/rDqndueunhc/" typeof="Book http://bibfra.me/vocab/lite/Item"><span property="name http://bibfra.me/vocab/lite/label"><a href="http://link.library.ibfd.org/portal/The-non-domiciled-alien-whose-RPHC-has-no-treaty/rDqndueunhc/">The non-domiciled alien whose RPHC has no treaty protection : coping with the anti-inversion rules of par. 7874</a></span> - <span property="potentialAction" typeOf="OrganizeAction"><span property="agent" typeof="LibrarySystem http://library.link/vocab/LibrarySystem" resource="http://link.library.ibfd.org/"><span property="name http://bibfra.me/vocab/lite/label"><a property="url" href="http://link.library.ibfd.org/">International Bureau of Fiscal Documentation</a></span></span></span></span></div>
