TITLE

International Tax Controversies

AUTHOR(S)
Fuller, James P.; Bassett, Barton W. S.
PUB. DATE
September 2006
SOURCE
Journal of Taxation of Global Transactions;Sep2006, Vol. 6 Issue 3, p23
SOURCE TYPE
Academic Journal
DOC. TYPE
Article
ABSTRACT
The article discusses issues concerning the new Internal Revenue Code Sec. 954(c)(6) introduced by the Tax Increase Prevention and Reconciliation Act of 2005 (TIPRA). The new Code provides a look-through exception to certain dividends, interest, rents, and royalties received by a controlled foreign corporation (CFC). Furthermore, it will facilitate a freer flow of funds within an international corporate group and help make U.S. companies more globally competitive.
ACCESSION #
24876739

 

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