News & Analysis as of

Parent Corporation › Churning

Fenwick & West LLP

New Field Attorney Advice Explores the Intersection of § 1253 with the Anti-Churning Rules of § 197

Fenwick & West LLP on

A new IRS legal advice memorandum addresses a fact pattern that may become more common in the wake of Tax Reform—sale of intangible property from a controlled foreign corporation to its United States parent—and highlights the...more

1 Results
 / 
View per page
Page: of 1

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
Sign up Log in
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide