Understanding Hedged Executory Contracts Under Tax Code
Hedged executory contract, agreement, and accounts transaction requirements for integration under Treasury Regulation Code Section 988(d) for taxpayers
Source: natlawreview.com
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Taxation of Foreign Currency Transactions Part III: Section 988 Transactions Defined, Character & Source | ASKramer Law
Which transactions qualify as section 988 transactions? In section 988 transactions, the taxpayer makes payments or receipts denominated in or determined by reference to one or more...
Source: jdsupra.com
Options for Treating Foreign Currencies as Section 988 Transactio
In section 988 transactions, the taxpayer makes payments or receipts determined by nonfunctional currencies, and include debt instrument transactions, RFCs, nonequit
Source: natlawreview.com
Treasury and IRS Issue Stock Buyback Excise Tax Guidance
Treasury Department and Internal Revenue Service IRS issue proposed Treasury Regulations to provide comprehensive guidance for applying one percent excise tax
Source: natlawreview.com
United States - Tax Authorities - Getting Technical With Partnership Termination Rule
The Tax Court recently ruled that a new partnership ("New Shoals") that is deemed to form on a technical termination may use a taxable year that starts...
Source: mondaq.com