Neither the Code nor the section 954 regulations provide specific guidance on whether a transaction entered into to manage exchange rate risk arising from a CFC’s net investment in a QBU can qualify as a bona fide hedging transaction eligible for the business needs exclusion.
If you want to change selection, open document below and click on "Move attachment"
pdf
owner:
VPLAN - (no access) - 2017-27320 988 regs.pdf, p10
Summary
status | not read | | reprioritisations | |
---|
last reprioritisation on | | | suggested re-reading day | |
---|
started reading on | | | finished reading on | |
---|
Details