The Resource Working with the new Section 367 indirect transfer and GRA rules

Working with the new Section 367 indirect transfer and GRA rules

Label
Working with the new Section 367 indirect transfer and GRA rules
Title
Working with the new Section 367 indirect transfer and GRA rules
Creator
Subject
Summary
This article describes the rules under Internal Revenue Code Section 367, focusing on two areas of interest to international tax practitioners and to taxpayers engaged in cross- border transactions: new indirect transfer rules and changes to the gain recognition agreement regime. Illustrated with examples it sets out the principal rules concerning outbound transfers of US corporation stock and securities, indirect stock and securities transfers under the gain recognition agreement (GRA) regime
Citation source
In: International tax journal. - New York. - Vol. 25 (1999),
http://library.link/vocab/creatorName
Lubin, M.L
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • outbound transaction
  • securities
  • triangular merger
Label
Working with the new Section 367 indirect transfer and GRA rules
Instantiates
Publication
Label
Working with the new Section 367 indirect transfer and GRA rules
Publication

Library Locations

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