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To ensure compliance with requirements imposed by the IRS, we inform you that any U.S. federal tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding tax-related penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or tax-related matter(s) addressed herein.

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Thursday, July 29, 2010

SubChapter M Tax: irs private letter ruling 201025031 - qualifying income under 851 from a CFC

SubChapter M Tax: irs private letter ruling 201025031 - qualifying income under 851 from a CFC: "This is in response to your letter dated August 9, 2009, requesting a ruling that (1) income and gain arising from the commodities-linked notes described below constitute qualifying income to Fund under section 851(b)(2) of the Internal Revenue Code of 1986, as amended (the “Code”) and (2) income earned from Fund’s investment in a wholly-owned subsidiary (Subsidiary) that is a controlled foreign corporation (CFC) under section 957(a) constitutes qualifying income to Fund under section 851(b)(2)."
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