Summer Ayers LePree

When Is A Statutory Benefit A ‘Treaty Benefit’? When IRS Says So!

Since Section 1(h)(11) was enacted as part of the Jobs and Growth Tax Relief Reconciliation Act of 2003, questions have been raised on exactly how to interpret the section's legislative history. Under this provision, a...more

10/19/2012 - Corporate Taxes Income Tax Treaty IRS Qualified Foreign Corporation