IRS Issues Final Rules on Treatment of Consolidated Groups
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IRS Issues Final Rules on Treatment of Consolidated Groups
The IRS issued final rules on February 22 that treat companies that are part of a consolidated group as a single entity for purposes of computing their share of certain foreign income. The rules (RIN 1545-BQ51) under I.R.C. Section 951(a)(2)(B) are meant to ensure that companies do not gain an advantage by shifting around the location of ownership of a foreign corporation’s stock from one entity to another within the group.
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