We found a match
Your institution may have access to this item. Find your institution then sign in to continue.
- Title
Tax Court Rejects IRS's Code Sec. 367(d) Argument.
- Authors
YODER, LOWELL D.
- Abstract
The article discusess various court cases in which U.S. Tax Court rejected various Internal Revenue Service's Code Section Sec. 367(d) arguments. Topics dicussed include section 367(d) concerning taxation of transfer of intangible property by U.S. domestic corporation to foreign subsidiary corporations on a contingent sale basis; court cases Hospital Corp. of America, Bausch & Lomb, Inc., and Merck & Co., Inc. on the same; and corporate tax law governing in the country.
- Subjects
UNITED States. Tax Court; UNITED States. Internal Revenue Service; TAXATION of intangible property; FOREIGN subsidiaries; HOSPITAL Corp. of America; BAUSCH &; Lomb Inc.; ACTIONS &; defenses (Law)
- Publication
International Tax Journal, 2017, Vol 43, Issue 6, p3
- ISSN
0097-7314
- Publication type
Article