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IRS Chief Counsel Memorandum Addresses 30-Day Rule Under Section 956
On Date 1, the CFC loaned Amount 1 to Parent. Amount 1 was outstanding on the last day of CFC's quarter including Date 1.
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IRS Concludes Fuel Credits Reduce Fuel Deduction When Taken Against Excise Tax Liability
The IRS has released a chief counsel advice memorandum (CCA 2014-06-001) that takes the position that refundable fuel tax credits reduce the deduction for fuel excise tax when they must first be used to offset excise tax liability.Grant Thornton LLP
