By dsstransky on February 27, 2008
Internal Revenue Code (“Code”) section 864(e), implemented through Temp. Treas. Reg. Sec. 1.861-11T, requires all members of a “domestic affiliated group” to be treated as one corporation for purposes of allocating interest expense between domestic and foreign source income. Therefore, by applying this rule, the foreign-source income derived from a foreign entity that incurs its [...]
Posted in Develop Your Skill
By dsstransky on February 11, 2008
In the world of international business, corporations that operate in different countries sometimes pursue reorganizations. They may do this to streamline operations to maintain a competitive advantage. They may also do it to change their corporate ‘persona’ with a new management and operating structure. When a multinational corporation reorganizes, it takes into consideration the tax [...]
Posted in Develop Your Skill
