Page 2 - Bar Panel News Today

Tax rate of those companies to be reduced. And thats why were talking about this subject. So it appears that having a bow tie is not an indication of prof sor yal stature but tax planning. John, you started us off by talking about the fact that your view, this set of practices were a symptom of a larger set of drivers in the Corporate Tax structure and that ultimately and i think you wouldnt get any disagreement with anyone here we need to be addressing those larger drivers. But in the context o...

Or in a number of different other circumstances guaranteed debts and the like. Those trigger a current inclusion of these deferred income thats been allowed to accrue tax free just like your i. R. A. Has been allowed to accrue tax free. And in code section 956, congress authorized treasury to write regulations to prevent the avoidance of the provisions of the section through reorganizations or otherwise. So, again, treasury has been given authority under this code section to tackle the kinds of ...

I just wanted to mention that one of the tools an Agency Always has is enforcement of the law as it is. And my article was directed at going expanding regulations to address issues that might not be able to reached under current law. But i didnt discuss in that article an antiabuse regulation under section 956 that as i read it, on its terms and because of some peculiar aspects that are quite expansive could actually be used to treat what is called a hopscotch loan from a controlled foreign subs...