United States. Congress, Affordable Health Care for America Act…
“ Treatment of fees and foreign taxes.—Fees and other transaction expenses and foreign taxes shall be taken into account as expenses in determining pre-tax profit under subparagraph (A) . `` (3) State and local tax benefits.—For purposes of paragraph (1) , any State or local income tax effect which is related to a Federal income tax effect shall be treated in the same manner as a Federal income tax effect. ”
United States. Congress, Affordable Health Care for America Act…
“ Foreign parent corporation.—For purposes of this subsection, the term ‘foreign parent corporation’ means, with respect to any deductible related-party payment, the common parent of the foreign controlled group of entities referred to in paragraph (3) (A) . ”
United States. Congress, Affordable Health Care for America Act…
“ Definitions and special rules.—For purposes of this subsection— `` (A) Economic substance doctrine.—The term ‘economic substance doctrine’ means the common law doctrine under which tax benefits under subtitle A with respect to a transaction are not allowable if the transaction does not have economic substance or lacks a business purpose. ”
