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Recapture of foreign loss does not exempt other gain from tax.
- Source :
- The Tax Adviser. February, 2024, Vol. 55 Issue 2,
- Publication Year :
- 2024
-
Abstract
- February 1, 2024 A multinational telecommunications company could not avoid recognizing gain on $2.8 billion of a $3.8 billion total gain from its sale of a Japanese controlled foreign corporation [...]
- Subjects :
- Tax exemption -- Laws, regulations and rules
Recognition of gain or loss (Taxation) -- Laws, regulations and rules
Controlled foreign corporations -- Mergers, acquisitions and divestments -- Laws, regulations and rules
Foreign source income taxation -- Laws, regulations and rules
Loss deductions -- Laws, regulations and rules
International business enterprises -- Laws, regulations and rules -- Mergers, acquisitions and divestments -- Taxation
Liberty Global, Inc. v. Commissioner (161 T.C. No. 10 (2023))
Government regulation
Company acquisition/merger
Internal Revenue Code (I.R.C. 904(f)(3)(A)(i)) (I.R.C. 1248) (I.R.C. 164(a)(3))
Subjects
Details
- Language :
- English
- ISSN :
- 00399957
- Volume :
- 55
- Issue :
- 2
- Database :
- Gale General OneFile
- Journal :
- The Tax Adviser
- Publication Type :
- Periodical
- Accession number :
- edsgcl.787578653