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Taxation & Estate Planning

: TaxProf Blog

Moin: Guarantee Fees and Container Corp.

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Andrew D. Moin (Sullivan & Cromwell, New York) has posted Guarantee Fees and Sourcing by Analogy: The Curious Case of Container Corporation on SSRN. Here is the abstract: The proper sourcing of payments to guarantee another?s obligations has long been ambiguous. The Tax Court, in its recent decision in Container...

Full post as published by TaxProf Blog on April 07, 2010 (boomark / email).

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