Reflections on Section 367(b) Regulations and Inbound Transactions

Columbia Journal of Tax Law

Paul W. Oosterhuis Mayté Quinn Salazar

What if the thinking behind Section 367(b) regulations, which relate to inbound transactions involving foreign corporations and U.S. tax, was flawed from the start? Of counsel Paul Oosterhuis and associate Mayté Quinn Salazar discuss shifting the focus to Section 1248 and hybrid dividend amounts.
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