... alternative tax bases and the usage of financial statement income in taxes have a long history in the United States, the tax represents a substantial change in the current corporate tax law. Although the corporate alternative minimum tax is predicted to raise billions of dollars from a small subset...

... provisions of Code Section 304 combined with the new 100 percent DRD of Code Section 245A, extracting earnings from affiliated foreign corporations tax-free has never been easier. This paper explains how these two code sections interact with each other and the resulting ability to extract certain foreign...

... April 2018 2018 corporate tax B reorganization Section 368 Section 351 aggregate method tracing method Due to the fact that both Code Section 351 and Code Section 368(a)(1)(B) may apply in this situation, the described transaction, although common and simple, is, unfortunately...