§318 Double-Inclusion Prohibition | International Tax Lawyers Tampa FL
In a previous article, I discussed the IRC (Internal Revenue Code) §318 general rule on the re-attribution of corporate stock; in that context, I mentioned that there are certain restrictions on §318 re-attribution. Today, I would like to discuss one of such restrictions – §318 double-inclusion prohibition. §318 Double-Inclusion Prohibition: General Re-Attribution Rule Before we […]