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Is critically important. Will talk about what the tax code provides. But there are a couple of markers. One time and the agency rewrite the statute. I heard this morning about the 80 , 50 . That would have to be done legislatively. That cannot be done through regulation. You can stretch out the statutes. You can elaborate on the statute and filling gaps. You cant rewrite it. Thats kind of a given. Another consideration is you can change your mind. The agency mightve said yes, yes, yes. And now saying no. Its okay. Youre allowed to change her mind. You have to explain why you are changing your mind. You have to provide information that justifies the change in position. But changing minds does not disqualify any kind of regulatory action. In the third marker that i want to lay down just because you have the authority doesnt mean you have to use it. And one of the issues that is discussed continuously within the executive branch is yes, you can do it. Do you want to . What are the consequ ....
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 subsidiary. If we had the picture back up i dont know if thats possible up to the new foreign parent as in many cases, not every case, but in many cases as a deemed dividend to the u. S. Company. So, the real need for regulations, in my view, is cases where that regulation with respect to using the offshore earnings would be cases like that regulation would not reach or that the i. R. S. Which has great discretion under that regulation chooses n ....