-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.Page: Previous 89 90 91 92 93 94 95 96 97 98 99 100 101 102 103 104 105 106 107 108 Next
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