Modifications to Sec. 956 made by the RRA. (Revenue Reconciliation Act of 1993): An article from: The Tax Adviser

This digital document is an article from The Tax Adviser, published by American Institute of CPA's on January 1, 1994. The length of the article is 736 words. The page length shown above is based on a typical 300-word page. The article is delivered in HTML format and is available in your Amazon.com Digital Locker immediately after purchase. You can view it with any web browser.

From the supplier: Changes in IRC Section 956 will limit the ability of taxpayers who are US shareholders in controlled foreign corporations to plan to avoid or take an inclusion of income from US investments by the controlled foreign corporation. Prior law allowed the taxpayer to compare the US investment to the previous year's amount at the end of the year, but the law now requires quarterly calculations. The quarterly method will make it less likely for the taxpayer that everything will average out over time. Section 956 will also require inclusions when a balance of US property is outstanding for a period of years while making actual distributions.

Citation Details
Title: Modifications to Sec. 956 made by the RRA. (Revenue Reconciliation Act of 1993)
Author: Marjorie A. Rollinson
Publication:The Tax Adviser (Magazine/Journal)
Date: January 1, 1994
Publisher: American Institute of CPA's
Volume: 25 Issue: n1 Page: 25(2)

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