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The § 367 Cross-Border Transfer Rules Seem to Counteract Other

question 88

Essay

The § 367 cross-border transfer rules seem to counteract other favorable tax provisions that allow the taxpayer to defer gross income (e.g. §§ 351 and 368.) What is the rationale for eliminating this deferral? Provide two examples of transactions to which § 367 would apply.


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A country in the Horn of Africa, known for its ancient civilizations, rich history, and diverse cultural heritage.

Fly-Whisk Hilt

The handle part of a fly-whisk, which is a traditional tool used to swat or shoo away flies, often intricately designed and made from various materials.

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A sculpting technique where a model is made in wax, covered with clay, melted out, and replaced with molten metal to form the sculpture.

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An object considered highly valuable or esteemed, often because of its rarity, craftsmanship, or association with power or wealth.

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