Basis increase denied to shareholder in related party loan restructuring

Article Abstract:

The most significant recent developments in the areas of partnerships, corporations, subchapter S, subchapter C, REITS, and qualified dividends are discussed. The rules of the proposed regulations apply to the transactions occurring after the date the regulations are published as final regulations in the Federal Register.

S corporations

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LTR revokes prior LTR that treated non-resident partners U.S sources income as exempt from U.S Taxation

Article Abstract:

A revoke is done on previous Ltr. Rul. 200420012 that deals with tax exemption of foreign companies having branch in United States in which partners are not residing in United States. All aspects of the law are discussed.

Tax Law, Public Finance Activities, Taxes, Interpretation and construction, Tax policy, Amendments (Parliamentary practice)

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