Page 400 - Large Business IRS Training Guides
P. 400
Special Rules for FDII
rules (including documentation guidelines) and
• Special
guidance are included in the proposed section 250
general
regulations.
• Statutorily, there are a small
number of special rules:
• Regarding Foreign Use in Domestic
Intermediary Transactions
Transactions
• Regarding Foreign Use in Related Party
• Related Party
Definition
• Congress was concerned with preventing “round-tripping”
that seek to circumvent the intent of
and other transactions
the 250 deduction.
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