We found a match
Your institution may have access to this item. Find your institution then sign in to continue.
- Title
Insolvent Foreign Subsidiaries.
- Authors
Cummings Jr., Jasper L.
- Abstract
The article focuses on the Generic Legal Advice Memorandum (GLAM) of the U.S. Internal Revenue Service (IRS) dated on August 18, 2011, which addresses the check-the-box liquidation of an insolvent foreign corporation. It says that the facts of GLAM differ from the revenue ruling only in that a foreign affiliate of parent owns a minority interest in the subsidiary. It adds that the bad debt loss is denied by GLAM because the business continues as a partnership that owes the liability.
- Subjects
UNITED States; MEMORANDUMS; UNITED States. Internal Revenue Service; LIQUIDATION; FOREIGN corporations; SUBSIDIARY corporations; BUSINESS partnerships; LIABILITIES (Accounting)
- Publication
Tax Executive, 2012, Vol 64, Issue 1, p41
- ISSN
0040-0025
- Publication type
Article