Branch Rule Final Regs. Tweak the 'Demonstrably' Greater Contribution and Grouping Rules

Journal of International Taxation
April 1, 2012

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.