In their column, Code Sec. 7874: Hotel California for U.S. Companies, Philip Tretiak and Patrick Jackman explain that recent IRS guidance has put Code Sec. 7874 back in the spotlight. The IRS and the Treasury have made it clear that they really want existing U.S. corporations and U.S. partnerships, even if they are insolvent, to stay right here in the United States.
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This story is from the CCH’s monthly Focus on Tax newsletter, which provides advise and guidance on federal and state tax issues for tax and accounting professionals.
Read this article from CCH’s Journal of Taxation of Financial Products