fully recognized in the transactionfrom either a US tax or foreign taxperspective. The Notice highlightsthe following transaction in whichtaxpayers have invoked the Statutory Disposition Rule "to avoid thepurpose of Section 901(m)."EY ...
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IRS Issues Foreign Tax Credit Guidelines under Section 901(M)Schwarz, Mel
Internal Revenue Service for partnership allocations of the Section 45 wind energy production tax credit for purposes of Section 704 (b). The article also contains the rules, legislations, and the requirements of the safe harbor as indicated by the revenue procedure.Birt...
IRS ruling resurrects Section 29 tax credit for well completions. (Internal Revenue Service)Garner, W. Lynn
IRS Releases Favorable Guidance for Individual Investors in Community Solar to Claim Section 25D Tax CreditKurt R. Rempe
Analyzes the voluntary financial disclosures and efforts of the U.S. Internal Revenue Service to uncover tax-avoidance plans involving the use of credit cards issued by offshore banks. Ned for the investigations; Impact of the disclosure policy on companies; Examples of timely voluntary disclosures....