Branch Rule Final Regs. Tweak the 'Demonstrably' Greater Contribution and Grouping Rules
On December 19, 2011, the IRS and the Treasury finalized Proposed Regulations which introduced a new way that a CFC/principal company (and its branches) could meet the manufacturing exception foreign base company sales income. Douglas S. Stransky co-wrote an article entitled “Branch Rule Regs. Tweak the 'Demonstrably Greater' Contribution and Grouping Rules,” published in the April 2012 edition of the Journal of International Taxation.