Your institution may have access to this item. Find your institution then sign in to continue.
Title
Working with the new Section 367 indirect transfer and GRA rules.
Abstract
Discusses Section 367 of the United States Internal Revenue Code which focuses on indirect transfer and gain recognition agreement (GRA) for domestic and foreign corporation stocks and securities. Changes in outbound transfer rules in 1998; Foreign corporation stock and securities transfers; Indirect stock transfers; Examples of asset transfers; Termination of GRA.