The Resource United Parcel Service of America v. Comr.: a new leading role for the assignment of income doctrine in Sec. 482 cases?

United Parcel Service of America v. Comr.: a new leading role for the assignment of income doctrine in Sec. 482 cases?

Label
United Parcel Service of America v. Comr.: a new leading role for the assignment of income doctrine in Sec. 482 cases?
Title
United Parcel Service of America v. Comr.: a new leading role for the assignment of income doctrine in Sec. 482 cases?
Creator
Subject
Summary
The article discusses the Tax Court's memorandum decision in United Parcel, with particular focus on its reliance upon the assignment of income doctrine in lieu of Sec. 482 or Sec. 845(a), both of which formed the specific ground for alternative arguments advanced by the Service. The article also considers the impact of the United Parcel decision on captive insurance arrangements generally
Citation source
In: Tax Management international journal. - Washington. - Vol. 29 (2000),
http://library.link/vocab/creatorName
Stansbury, C.B
Language note
English
http://library.link/vocab/subjectName
  • case law
  • transfer pricing
  • captive insurance company
Label
United Parcel Service of America v. Comr.: a new leading role for the assignment of income doctrine in Sec. 482 cases?
Instantiates
Publication
Label
United Parcel Service of America v. Comr.: a new leading role for the assignment of income doctrine in Sec. 482 cases?
Publication

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.37366609999999 4.9336932
Processing Feedback ...