VIEWPOINT: The Branch Rule: An Unhurried Read of the Statute

H. David Rosenbloom is a member with Caplin & Drysdale in Washington, the James S. Eustice Visiting Professor of Taxation and the director of the international tax program at New York University School of Law, and a member of Tax Analysts’ board of directors.

In this article, Rosenbloom considers the language of the branch rule of subpart F and whether it should apply to both sales and manufacturing branches.

Copyright 2022 H. David Rosenbloom. All rights reserved.

For the full article, please visit Tax Notes' website (subscription required) or click the PDF link above