IRS Rules On Application Of Tax Rate Disparity Test - Congoo

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IRS Rules on Application of Tax Rate Disparity Test

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Tax Notes Today | November 07, 2009

Citations: LTR 200945036 Date: Jul. 27, 2009 The IRS has ruled that for purposes of applying the manufacturing branch rule under section 954, payments by a CFC of taxes other than income taxes -- such as VAT -- are not considered for purposes of the tax rate disparity test. [View as PDF] [Third Part...

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