This site uses cookies to store information on your computer. Some are essential to make our site work; others help us improve the user experience. By using the site, you consent to the placement of these cookies. Read our privacy policy to learn more.

Technical

Issues Involving the Interplay of Subpart F Income Recapture Account and Sec. 956 Inclusion

Read now

Treavor Weeden, CPA and Hui Yu, J.D., LL.M. | Free | AICPA | 01 Jul 2016 | Tax Adviser Magazine

US anti-deferral rules
Intermediate
Article

0 Save

Save

Description
Comments/Reflections

Treating a Sec. 956 inclusion as not a distribution for purposes of Regs. Sec. 1.952-1(f)(2)(iii) leads to unintended results under certain fact patterns. This article explores the issues.

Topics covered:

Tax: Technical: International tax: US anti-deferral rules, Intermediate

Comments/Reflections

Read now

Technical

Issues Involving the Interplay of Subpart F Income Recapture Account and Sec. 956 Inclusion

Comments/Reflections

You may also be interested in:

Article

Avoiding Cost Segregation Recapture Tax

Article

Determining the Taxability of S Corporation Distributions: Part I - S CORPORATIONS

Explore Topics