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The 4th Amended Finance Act for 2011 introduces a specific anti abuse mechanism designed to defeat the artificial allocation to a French corporation of debt in relation to the acquisition of shares of an entity (other than a real estate company) which is not controlled from France
As part of the American Jobs Creation Act of 2004 (the 2004 Act), Section 108(e)(8) of the Internal Revenue Code of 1986 (the Code) was amended to address discharges of partnership indebtedness when a partnership transfers a partnership equity interest to satisfy a partnership debt
