In 1998 the IRS and the Treasury Department got the attention of the outbound international tax community by issuing Notice 98-5. The notice sought to challenge certain tax-motivated transactions that generated foreign tax credits (FTCs) by testing their substance under an economic profits test. The transactions described in Notice 98-5 were later included as "listed transactions" subject to the tax shelter disclosure, registration and list maintenance requirements.
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Building a transparent culture, prioritising internal promotions and being different from the big four are all key features of A&M Tax’s ambitious plans for India
But businesses should remain flexible when choosing between internal and external resources to handle added ViDA complexity, ITR’s Indirect Tax forum also heard