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Proposed Section 892 regulations provide relief from the “all or nothing” rule and permit SWF Limited partners to avoid commercial activity attribution

USA - November 8 2011 Proposed regulations issued under Internal Revenue Code section 892, on November 2, 2011, address some of the most criticized rules under temporary regulations issued more than 20 years ago.

Dwaune L. Dupree, Daniel R. McKeithen, Carol P. Tello