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Author: The Law The Law Library Publisher: Createspace Independent Publishing Platform ISBN: 9781729711187 Category : Languages : en Pages : 34
Book Description
Inversions and Related Transactions - Guidance for Determining Stock Ownership (US Internal Revenue Service Regulation) (IRS) (2018 Edition) The Law Library presents the complete text of the Inversions and Related Transactions - Guidance for Determining Stock Ownership (US Internal Revenue Service Regulation) (IRS) (2018 Edition). Updated as of May 29, 2018 This document contains final regulations that identify certain stock of a foreign corporation that is disregarded in calculating ownership of the foreign corporation for purposes of determining whether it is a surrogate foreign corporation. These regulations also provide guidance on the effect of transfers of stock of a foreign corporation after the foreign corporation has acquired substantially all of the properties of a domestic corporation or of a trade or business of a domestic partnership. These regulations affect certain domestic corporations and partnerships (and certain parties related thereto) and foreign corporations that acquire substantially all of the properties of such domestic corporations or of the trades or businesses of such domestic partnerships. The text of the temporary regulations also serves as the text of the proposed regulations set forth in the notice of proposed rulemaking on Rules Regarding Inversions and Related Transactions in the Proposed Rules section of this issue of the Federal Register. This book contains: - The complete text of the Inversions and Related Transactions - Guidance for Determining Stock Ownership (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: 9781729711187 Category : Languages : en Pages : 34
Book Description
Inversions and Related Transactions - Guidance for Determining Stock Ownership (US Internal Revenue Service Regulation) (IRS) (2018 Edition) The Law Library presents the complete text of the Inversions and Related Transactions - Guidance for Determining Stock Ownership (US Internal Revenue Service Regulation) (IRS) (2018 Edition). Updated as of May 29, 2018 This document contains final regulations that identify certain stock of a foreign corporation that is disregarded in calculating ownership of the foreign corporation for purposes of determining whether it is a surrogate foreign corporation. These regulations also provide guidance on the effect of transfers of stock of a foreign corporation after the foreign corporation has acquired substantially all of the properties of a domestic corporation or of a trade or business of a domestic partnership. These regulations affect certain domestic corporations and partnerships (and certain parties related thereto) and foreign corporations that acquire substantially all of the properties of such domestic corporations or of the trades or businesses of such domestic partnerships. The text of the temporary regulations also serves as the text of the proposed regulations set forth in the notice of proposed rulemaking on Rules Regarding Inversions and Related Transactions in the Proposed Rules section of this issue of the Federal Register. This book contains: - The complete text of the Inversions and Related Transactions - Guidance for Determining Stock Ownership (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: 9781729711156 Category : Languages : en Pages : 122
Book Description
Inversions and Related Transactions (US Internal Revenue Service Regulation) (IRS) (2018 Edition) The Law Library presents the complete text of the Inversions and Related Transactions (US Internal Revenue Service Regulation) (IRS) (2018 Edition). Updated as of May 29, 2018 This document contains temporary regulations that address transactions that are structured to avoid the purposes of sections 7874 and 367 of the Internal Revenue Code (the Code) and certain post-inversion tax avoidance transactions. These regulations affect certain domestic corporations and domestic partnerships whose assets are directly or indirectly acquired by a foreign corporation and certain persons related to such domestic corporations and domestic partnerships. The text of the temporary regulations also serves as the text of the proposed regulations set forth in the notice of proposed rulemaking on this subject in the Proposed Rules section of this issue of the Federal Register. The final regulations revise and add cross-references to coordinate the application of the temporary regulations. This book contains: - The complete text of the Inversions and Related Transactions (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: 9781729704868 Category : Languages : en Pages : 26
Book Description
Guidance for Determining Stock Ownership (US Internal Revenue Service Regulation) (IRS) (2018 Edition) The Law Library presents the complete text of the Guidance for Determining Stock Ownership (US Internal Revenue Service Regulation) (IRS) (2018 Edition). Updated as of May 29, 2018 This document contains temporary regulations that identify certain stock of a foreign corporation that is disregarded in calculating ownership of the foreign corporation for purposes of determining whether it is a surrogate foreign corporation. These regulations also provide guidance with respect to the effect of transfers of stock of a foreign corporation after the foreign corporation has acquired substantially all of the properties of a domestic corporation or of a trade or business of a domestic partnership. These regulations affect certain domestic corporations and partnerships (and certain parties related thereto), and foreign corporations that acquire substantially all of the properties of such domestic corporations or of the trades or businesses of such domestic partnerships. The text of the temporary regulations serves as the text of the proposed regulations set forth in the Proposed Rules section in this issue of the Federal Register. This document also contains a final regulation that provides a cross-reference to the temporary regulations. This book contains: - The complete text of the Guidance for Determining Stock Ownership (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: 9781729734568 Category : Languages : en Pages : 34
Book Description
Surrogate Foreign Corporations (US Internal Revenue Service Regulation) (IRS) (2018 Edition) The Law Library presents the complete text of the Surrogate Foreign Corporations (US Internal Revenue Service Regulation) (IRS) (2018 Edition). Updated as of May 29, 2018 This document contains final regulations regarding whether a foreign corporation is treated as a surrogate foreign corporation. The final regulations affect certain domestic corporations and partnerships (and certain parties related thereto), and foreign corporations that acquire substantially all of the properties of such domestic corporations or partnerships. This book contains: - The complete text of the Surrogate Foreign Corporations (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: 9781729691175 Category : Languages : en Pages : 46
Book Description
Definitions and Reporting Requirements for Shareholders of Passive Foreign Investment Companies (US Internal Revenue Service Regulation) (IRS) (2018 Edition) The Law Library presents the complete text of the Definitions and Reporting Requirements for Shareholders of Passive Foreign Investment Companies (US Internal Revenue Service Regulation) (IRS) (2018 Edition). Updated as of May 29, 2018 This document contains final regulations that provide guidance on determining ownership of a passive foreign investment company (PFIC) and on certain annual reporting requirements for shareholders of PFICs to file Form 8621, "Information Return by a Shareholder of a Passive Foreign Investment Company or Qualified Electing Fund." In addition, the final regulations provide guidance on an exception to the requirement for certain shareholders of foreign corporations to file Form 5471, "Information Return of U.S. Persons with Respect to Certain Foreign Corporations." The regulations finalize proposed regulations and withdraw temporary regulations published on December 31, 2013. The final regulations affect United States persons that own interests in PFICs, and certain United States shareholders of foreign corporations. This book contains: - The complete text of the Definitions and Reporting Requirements for Shareholders of Passive Foreign Investment Companies (US Internal Revenue Service Regulation) (IRS) (2018 Edition) - A table of contents with the page number of each section
Author: Charles H. Gustafson Publisher: West Academic Publishing ISBN: 9780314911711 Category : Casebooks Languages : en Pages : 0
Book Description
Designed for use in law schools, business schools and schools of management, this casebook outlines the determination and administration of U.S. income tax liabilities resulting from international transactions. Textual discussion, cases, rulings and problems, guides students through the basic tax considerations that confront foreign individuals and entities participating in the U.S. economy, and U.S. individuals and entities seeking to derive income abroad. Covers both the U.S. tax rules applicable to international transactions and the tax policy considerations underlying those rules.
Author: Lucas Chancel Publisher: Harvard University Press ISBN: 0674273567 Category : Business & Economics Languages : en Pages : 267
Book Description
World Inequality Report 2022 is the most authoritative and comprehensive account of global trends in inequality, providing cutting-edge information about income and wealth inequality and also pioneering data about the history of inequality, gender inequality, environmental inequalities, and trends in international tax reform and redistribution.