CCH Tax Day Report The “bearer-share regulations,” which preclude a foreign corporation with bearer shares from using those shares to establish the corporation eligibility to exempt certain income from U.S. taxation, were valid under the two-step Chevron analysis. Congress did not directly address how a foreign corporation seeking the benefits of Code Sec. 833(a)(1) could […]
The post Bearer-Share Regulations Valid; Passed Two-Step Chevron Test (Good Fortune Shipping SA, TC) appeared first on Tax & Accounting Blog.