VIEWPOINT: The Branch Rule: An Unhurried Read of the Statute
H. David Rosenbloom is a member with Caplin & Drysdale in Washington, the James S. Eustice Visiting Professor of Taxation and the director of the international tax program at New York University School of Law, and a member of Tax Analysts’ board of directors.
In this article, Rosenbloom considers the language of the branch rule of subpart F and whether it should apply to both sales and manufacturing branches.
Copyright 2022 H. David Rosenbloom. All rights reserved.
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