The AICPA supplied Treasury with comments citing that the definition of “issue under consideration” for certain foreign corporations contained in the Revenue Procedures effectively precludes many United States (U.S.) multinational corporations from voluntarily complying with proper tax accounting principles by filing applications for accounting method changes on behalf of their controlled foreign corporations or 10/50 corporations (collectively “foreign corporations”) either under Revenue Procedure 2011-14 (for an automatic method change) or under Revenue Procedure 97-27 (for a nonautomatic method change).
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AICPA Comments on Revenue Procedure 2011-14 and Revenue Procedure 97-27
Jul 30, 2012 · 212.8 KB Download
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Download the AICPA Comments on Revenue Procedure 2011-14 and Revenue Procedure 97-27
File name: 2012-07-30 Treasury - Foreign Corp 3115 Issue Consideration.pdf
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