Editor's note

Code Section 482 and its predecessor deal with transactions between parties under common control, and Subpart F was created to impute income to parties that had controlled foreign corporations. Congress devoted an entire section of the Internal Revenue Code to defining "control," and the T...

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Bibliographic Details
Published in:International tax journal 1999-07, Vol.25 (3), p.III
Main Author: O'Connor, Walter F
Format: Article
Language:English
Subjects:
Consolidated tax returns
Control
Controlled foreign corporations
Corporate taxes
Editorials
Internal Revenue Code
International
Multinational corporations
Personal holding companies
Section 482
Online Access:Get full text
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Summary:Code Section 482 and its predecessor deal with transactions between parties under common control, and Subpart F was created to impute income to parties that had controlled foreign corporations. Congress devoted an entire section of the Internal Revenue Code to defining "control," and the Treasury regulations under Subpart F contain many pages addressing that subject. However, it does not address the issue of economic control.
ISSN:0097-7314