Sale of shares to related companies : the surprising tax consequences of U.S. Internal Revenue Code Sec. 304

Journal
Brewer, K.
Bulletin for International Taxation 2001 (Volume 55), No. 9
PriceUSD 45

Explores some routine cases to illustrate the kinds of surprises that Sec. 304 can have for foreign shareholders. Also provides background on how and why Sec. 304 works the way it does and gives some suggestions on how to plan, or in some cases argue, around the adverse consequences of Sec. 304.