Comment Letter: Proposed Change to Section 901 Definition of Foreign Tax
University of Houston Law Center
August 20, 2010
Tax Notes Today, Vol. 2007, p. 160, 2007
U of Houston Law Center No. 2010-A-25
This letter comments on proposed regulations that would disallow foreign tax credits with respect to certain passive structure investments. The letter argues that the proposed regulations are not well-reasoned and should be substantially revised along the lines advocated in the letter.
Number of Pages in PDF File: 10
Keywords: foreign tax credits, foreign tax credit generator transactions, passive structured investmentsAccepted Paper Series
Date posted: August 23, 2010
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