Business Services Industry
Why the sandwich structure problem needs innovative solutions.
Australasian Business Intelligence, December, 2005
Byline: Jack Cummings and Edward Tanenbaum
Dec 02, 2005 (International Tax Review - ABIX via COMTEX) -- The US Internal Revenue Service has recently issued ruling PLR 200532036. The document deals with the problem of a so-called sandwich in a cross-border holding company structure. The ruling gives a foreign shareholder the right to claim an indirect foreign tax credit for taxes paid by a foreign subsidiary owned by the foreign shareholder's US consolidated group by applying section 355 to the distribution.
Publication Date: November 2005
UNITED STATES. INTERNAL REVENUE SERVICE
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