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Title
Comments on applicability of Notice 88-108 after OBRA 1993.
Abstract
Discusses the comments filed by the Tax Executives Institute (TEI) with the United States Treasury Department and the Internal Revenue Service (IRS) regarding the applicability of section 956 of the Internal Revenue Code after the enactment of the Omnibus Budget Reconciliation Act (OBRA) of 1993. Taxation treatment of investments by a controlled foreign corporation in a United States property.