Transfer Pricing Report

Treasury Eyes Help for Ordering Overlapping Tax Calculations (1)

Nov. 15, 2019, 9:56 PMUpdated: Nov. 15, 2019, 11:05 PM

Treasury is considering how to address ordering issues for taxpayers that are subject to several overlapping taxable income limitations.

“We may do a separate package on all these ordering rules” but no decision has been made by Treasury yet, said Brenda Zent, special adviser to the international tax counsel in Treasury’s Office of Tax Policy, at the American Institute of CPAs conference Nov. 15.

  • The issue arises from several tax calculations depending on the outcome of other tax calculations, creating a “chicken and egg” problem that complicates the process for taxpayers that don’t know which rules to apply...
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