A company without a country: the dual consolidated loss regime

Resource Information

The work A company without a country: the dual consolidated loss regime represents a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation. This resource is a combination of several types including: Work, Language Material, Continuing Resources.

Label

A company without a country: the dual consolidated loss regime

Creator

• Hardy, D.R

Subject

• hybrid entity
• dual residence
• losses

Summary

This report considers the use of hybrid entities in capital intensive foreign infrastructure acquisitions. The author attempts to describe particular situations where the use of entities subject to the US dual consolidated loss (DCL) rules will make important planning sense, and the responses of both the United States and other countries to such dual resident companies are compared

Citation source

In: Tax Notes. - Arlington. - Vol. 84 (1999),

Language note

English