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

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
Creator
Subject
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
Instantiates
Publication
Label
The non-domiciled alien whose RPHC has no treaty protection : coping with the anti-inversion rules of par. 7874
Publication

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