73
See Reg. 1.1503(d). 74
Reg. 1.1503(d)-1(b)(3). 75
TD 9315, 3/16/07.
76
Reg. 1.1503(d)-1(b)(2). “TE
TD 9315, 3/16/07.
78
Id.; Section 1503(d)(1). The DCL rules also specifically speak about situations involving “transparent entities,” which are uniquely defined for purposes of the DCL rules.
WLS) See generally Reg. 1.1503(d)-5.
80
There are also other narrow areas where the IRS has indicated it will treat a DRE as separate from its sole owner, such as the foreign exchange rules under Section 987 in the case of certain DREs that are qualified business units and have a different functional currency than their U.S. parent.
81
See Dept. of Treasury, General Explanations of the Administration's Fiscal Year 2010 Revenue Proposals (May 2009),
82
President Obama announced the proposal during his 5/4/09 news conference regarding combating tax havens.
83
See supra footnote 77.
© 2009 Thomson Reuters/RIA. All rights reserved.
HOUSE_OVERSIGHT_026597