Layla Asali Comments on Anti-Loss Importation Regulations in Tax Notes Today

"Alexander Sheds Light on Meaning of No-Rule's 'in Anticipation of' a Spinoff"
Tax Notes Today
03.03.14Speaking at the recent corporate tax developments session of the Federal Bar Association (FBA) Section on Taxation annual meeting, Layla Asali queried Internal Revenue Service (IRS) Deputy Chief Counsel (Technical) Erik Corwin on proposed section 362(e)(1) anti-loss importation regulations. Corwin addressed the special rule treating as "subject to U.S. tax" some passthrough entities, including domestic trusts, estates, regulated investment companies, real estate investment trusts and cooperatives. He observed that applying a look-through rule to such entities would have been "somewhat burdensome" and indicated that the government is interested in comments on whether publicly traded partnerships should similarly be treated as subject to U.S. tax, or whether they should instead be subject to the look-through rule generally applicable to partnerships.
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