-99-
application by the courts of a foreign corporation filing
deadline for purposes of the predecessor of section 882(c)(2).
Section 1.882-4(a)(2) and (3)(i) and (ii), Income Tax
Regs., reflects the Commissioner’s and the Secretary’s
consistent and similar conclusion. The specific foreign
corporation tax return filing deadline that is reflected in the
regulation incorporates aspects of the judicially crafted
deadline, is flexible to take into account unusual situations,
but also is modestly tightened up to reflect updated tax
administration concerns relating to foreign corporate tax
compliance.
For the reasons stated, I respectfully dissent from this
Opinion which invalidates section 1.882-4(a)(2) and (3)(i),
Income Tax Regs.
HOLMES, J., agrees with this dissenting opinion.
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