Dual Consolidated Loss Regulations (Us Internal Revenue Service Regulation) (Irs) (2018 Edition)

Dual Consolidated Loss Regulations (Us Internal Revenue Service Regulation) (Irs) (2018 Edition) PDF

Author: The Law The Law Library

Publisher: Createspace Independent Publishing Platform

Published: 2018-11-07

Total Pages: 102

ISBN-13: 9781729691977

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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

Unified Rule for Loss on Subsidiary Stock (Us Internal Revenue Service Regulation) (Irs) (2018 Edition)

Unified Rule for Loss on Subsidiary Stock (Us Internal Revenue Service Regulation) (Irs) (2018 Edition) PDF

Author: The Law The Law Library

Publisher: Createspace Independent Publishing Platform

Published: 2018-11-12

Total Pages: 124

ISBN-13: 9781729735572

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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

United States Code

United States Code PDF

Author: United States

Publisher:

Published: 2013

Total Pages: 1506

ISBN-13:

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"The United States Code is the official codification of the general and permanent laws of the United States of America. The Code was first published in 1926, and a new edition of the code has been published every six years since 1934. The 2012 edition of the Code incorporates laws enacted through the One Hundred Twelfth Congress, Second Session, the last of which was signed by the President on January 15, 2013. It does not include laws of the One Hundred Thirteenth Congress, First Session, enacted between January 2, 2013, the date it convened, and January 15, 2013. By statutory authority this edition may be cited "U.S.C. 2012 ed." As adopted in 1926, the Code established prima facie the general and permanent laws of the United States. The underlying statutes reprinted in the Code remained in effect and controlled over the Code in case of any discrepancy. In 1947, Congress began enacting individual titles of the Code into positive law. When a title is enacted into positive law, the underlying statutes are repealed and the title then becomes legal evidence of the law. Currently, 26 of the 51 titles in the Code have been so enacted. These are identified in the table of titles near the beginning of each volume. The Law Revision Counsel of the House of Representatives continues to prepare legislation pursuant to 2 U.S.C. 285b to enact the remainder of the Code, on a title-by-title basis, into positive law. The 2012 edition of the Code was prepared and published under the supervision of Ralph V. Seep, Law Revision Counsel. Grateful acknowledgment is made of the contributions by all who helped in this work, particularly the staffs of the Office of the Law Revision Counsel and the Government Printing Office"--Preface.

Neutralising the Effects of Branch Mismatch Arrangements, Action 2

Neutralising the Effects of Branch Mismatch Arrangements, Action 2 PDF

Author: Organization for Economic Development and Cooperation

Publisher: Organization for Economic Co-Operation & Development

Published: 2017

Total Pages: 0

ISBN-13: 9789264277953

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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.

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