IRS finalizes Sec. 304 anti-abuse regulations

12/24/2012 | JournalofAccountancy.com

The Internal Revenue Service on Friday issued final regulations designed to prevent corporations from avoiding the application of Sec. 304 to transactions in which they repatriate earnings from foreign subsidiaries. The regulations finalize temporary rules issued in 2009 and have a Dec. 29, 2009, effective date.

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