News Analysis: Assisting Income Stripping and Subpart F Avoidance


Lowell Yoder was one of three leading tax practitioners who interviewed a senior IRS lawyer about the agency’s plans to offer future guidance on such issues as differentiating sales income from services income, commodity rules for foreign personal holding company income, and branch rules for subpart F. On the latter issue Mr. Yoder pointed out that IRS regulations expressly apply the sales branch rule only to income arising from actual purchasing or selling activities on the part of the branch.