Dual Consolidated Loss Regulations (Us Internal Revenue Service Regulation) (Irs) (2018 Edition) PDF Download
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Author: The Law The Law Library
Publisher: Createspace Independent Publishing Platform
ISBN: 9781729691977
Category :
Languages : en
Pages : 102
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Book Description
Dual Consolidated Loss Regulations (US Internal Revenue Service Regulation) (IRS) (2018 Edition) The Law Library presents the complete text of the Dual Consolidated Loss Regulations (US Internal Revenue Service Regulation) (IRS) (2018 Edition). Updated as of May 29, 2018 This document contains final regulations under section 1503(d) of the Internal Revenue Code (Code) regarding dual consolidated losses. Section 1503(d) generally provides that a dual consolidated loss of a dual resident corporation cannot reduce the taxable income of any other member of the affiliated group unless, to the extent provided in regulations, the loss does not offset the income of any foreign corporation. Similar rules apply to losses of separate units of domestic corporations. These final regulations address various dual consolidated loss issues, including exceptions to the general prohibition against using a dual consolidated loss to reduce the taxable income of any other member of the affiliated group. This book contains: - The complete text of the Dual Consolidated Loss Regulations (US Internal Revenue Service Regulation) (IRS) (2018 Edition) - A table of contents with the page number of each section
Author: The Law The Law Library
Publisher: Createspace Independent Publishing Platform
ISBN: 9781729691977
Category :
Languages : en
Pages : 102
Get Book
Book Description
Dual Consolidated Loss Regulations (US Internal Revenue Service Regulation) (IRS) (2018 Edition) The Law Library presents the complete text of the Dual Consolidated Loss Regulations (US Internal Revenue Service Regulation) (IRS) (2018 Edition). Updated as of May 29, 2018 This document contains final regulations under section 1503(d) of the Internal Revenue Code (Code) regarding dual consolidated losses. Section 1503(d) generally provides that a dual consolidated loss of a dual resident corporation cannot reduce the taxable income of any other member of the affiliated group unless, to the extent provided in regulations, the loss does not offset the income of any foreign corporation. Similar rules apply to losses of separate units of domestic corporations. These final regulations address various dual consolidated loss issues, including exceptions to the general prohibition against using a dual consolidated loss to reduce the taxable income of any other member of the affiliated group. This book contains: - The complete text of the Dual Consolidated Loss Regulations (US Internal Revenue Service Regulation) (IRS) (2018 Edition) - A table of contents with the page number of each section
Author: The Law The Law Library
Publisher: Createspace Independent Publishing Platform
ISBN: 9781729735572
Category :
Languages : en
Pages : 124
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Book Description
Unified Rule for Loss on Subsidiary Stock (US Internal Revenue Service Regulation) (IRS) (2018 Edition) The Law Library presents the complete text of the Unified Rule for Loss on Subsidiary Stock (US Internal Revenue Service Regulation) (IRS) (2018 Edition). Updated as of May 29, 2018 This document contains final regulations under sections 358, 362(e)(2), and 1502 of the Internal Revenue Code (Code). The regulations apply to corporations filing consolidated returns, and corporations that enter into certain tax-free reorganizations. The regulations provide rules for determining the tax consequences of a member's transfer (including by deconsolidation and worthlessness) of loss shares of subsidiary stock. In addition, the regulations provide that section 362(e)(2) generally does not apply to transactions between members of a consolidated group. Finally, the regulations conform or clarify various provisions of the consolidated return regulations, including those relating to adjustments to subsidiary stock basis. This book contains: - The complete text of the Unified Rule for Loss on Subsidiary Stock (US Internal Revenue Service Regulation) (IRS) (2018 Edition) - A table of contents with the page number of each section
Author: United States
Publisher:
ISBN:
Category : Law
Languages : en
Pages : 1420
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Book Description
Author:
Publisher:
ISBN:
Category : Agricultural laborers
Languages : en
Pages : 48
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Author: Organization for Economic Development and Cooperation
Publisher: Organization for Economic Co-Operation & Development
ISBN: 9789264277953
Category : Corporations
Languages : en
Pages : 0
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Book Description
This 2017 report sets out recommendations for branch mismatch rules that would bring the treatment of these structures into line with the treatment of hybrid mismatch arrangements as set out in the 2015 Report on Neutralising the Effects of Hybrids Mismatch Arrangements (Action 2 Report). Branch mismatches arise where the ordinary rules for allocating income and expenditure between the branch and head office result in a portion of the net income of the taxpayer escaping the charge to taxation in both the branch and residence jurisdiction. Unlike hybrid mismatches, which result from conflicts in the legal treatment of entities or instruments, branch mismatches are the result of differences in the way the branch and head office account for a payment made by or to the branch. The 2017 report identifies five basic types of branch mismatch arrangements that give rise to one of three types of mismatches: deduction / no inclusion (D/NI) outcomes, double deduction (DD) outcomes, and indirect deduction / no inclusion (indirect D/NI) outcomes. This report includes specific recommendations for improvements to domestic law intended to reduce the frequency of branch mismatches as well as targeted branch mismatch rules which adjust the tax consequences in either the residence or branch jurisdiction in order to neutralise the hybrid mismatch without disturbing any of the other tax, commercial or regulatory outcomes. The annexes of the report summarise the recommendations and set out a number of examples illustrating the intended operation of the recommended rules.
Author: United States. Internal Revenue Service
Publisher:
ISBN:
Category : Income tax
Languages : en
Pages : 32
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Book Description
Author: OECD
Publisher: OECD Publishing
ISBN: 9264241132
Category :
Languages : en
Pages : 458
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Book Description
Addressing base erosion and profit shifting (BEPS) is a key priority of governments. In 2013, OECD and G20 countries, working together on an equal footing, adopted a 15-point Action Plan to address BEPS. This publication is the final report for Action 2.
Author: United States. Internal Revenue Service
Publisher:
ISBN:
Category : Annuities
Languages : en
Pages : 32
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Book Description
Author:
Publisher:
ISBN:
Category : Income tax
Languages : en
Pages : 1412
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Author: United States. Department of Justice
Publisher:
ISBN:
Category : Justice, Administration of
Languages : en
Pages : 718
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Book Description