New Rules on Covered Asset Acquisitions Will Shut Down Transactions to Avoid Sec. 901(m)

The IRS will issue regulations to prevent taxpayers from misapplying the statutory disposition rule in cases where the gain or loss from the disposition of the relevant foreign asset is recognized for U.S. income tax purposes but not for foreign income tax purposes.

Source: http://feedproxy.google.com/~r/AICPA_TaxAdvisor/~3/ymBqk0eToIY/20140721.aspx

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