The IRS Proposes a New Approach to Determine the Technical Taxpayer--Will It Work?

Dabrowski, Ron; Shein, Caren
September 2006
Journal of Taxation of Global Transactions;Sep2006, Vol. 6 Issue 3, p63
Academic Journal
The article discusses the application of the Proposed Regulations by the U.S. Internal Revenue Service to determine the technical taxpayer for the U.S. tax purposes. The Proposed Regulations focus in three areas: withholding tax, foreign consolidated groups, and reverse hybrids. The proposal approached to foreign tax credit to prevent double taxation of income, as withholding taxes are imposed on items of income not on persons.


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