Notice 2020-47, 2020-2021 Priority Guidance Plan Submission

83 Pages Posted: 18 Aug 2020

See all articles by Jeffery M. Kadet

Jeffery M. Kadet

University of Washington - School of Law

Date Written: July 16, 2020

Abstract

This lengthy submission includes recommendations in a number of international tax areas for regulation changes, improvements, and modernization. It includes for a number of areas suggested regulatory language that could be considered.

Much of the submission concerns sourcing and effectively connected income rules. It also covers the existence of unanticipated partnerships among an MNC's group members that conduct joint business activities. Regarding subpart F, it makes suggestions concerning the manufacturing branch rule. Finally, it includes suggestions regarding the manner in which tax treaties should or should not apply to certain hybrid entities.

Keywords: ECI, Effectively Connected Income, Tax Treaties, Source of Income, Transfer Pricing, §482, Partnership, Check-the-Box, Entity Classification Rules, Subpart F, Branch Rule,

JEL Classification: H21, H25, K34, E62

Suggested Citation

Kadet, Jeffery M., Notice 2020-47, 2020-2021 Priority Guidance Plan Submission (July 16, 2020). Available at SSRN: https://ssrn.com/abstract=3653543 or http://dx.doi.org/10.2139/ssrn.3653543

Jeffery M. Kadet (Contact Author)

University of Washington - School of Law ( email )

William H. Gates Hall
Box 353020
Seattle, WA 98105-3020
United States

Do you have a job opening that you would like to promote on SSRN?

Paper statistics

Downloads
24
Abstract Views
347
PlumX Metrics