Sec. 894 final rules for recharacterizing deductible payments.
The Tax Adviser › Vol. 34 Nbr. 3, March 2003
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Sec. 894 final rules for recharacterizing deductible payments.
Sec. 894 final regulations address payments made by domestic reverse hybrid entities (DRHs). In certain cases, these regulations can characterize deductible payments that a DRH makes to a related foreign interest holder (RFIH) as nondeductible dividend payments. They are effective for payments that the DRH makes or receives after June 11,2002.
Targeted Transactions According to Regs. Sec. 1.894-...See the full content of this document
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