Financing International Operations

Harter, L. G.; Harper, Michael J.
September 2006
Journal of Taxation of Global Transactions;Sep2006, Vol. 6 Issue 3, p11
Academic Journal
The article discusses the implication of the Notice 2005-90 on the potential application of Internal Revenue Code Sec. 901(l) to certain related-party royalty payments issued by the U.S. Internal Revenue Service. The Notice illustrates how the Code could be applied to deny foreign tax credits in a wide range of licensing, leasing and financing arrangements. The Notice proposed exception that covers a specific type of back-to-back computer software licensing arrangement.


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