| | Tax Executive, The: TEI proposal to extend the period to make section 936 elections - h - Tax Executives Institute (Site not responding. Last check: 2007-11-07) |
 | | Pursuant to section 936(h) of the Code, taxpayers may elect either the cost-sharing or profit-split method for the calculation of their section 936 credit. |
 | | Thus, no election should be required until guidance is provided on the application of the statutory changes to section 482 in the context of section 936. |
 | | If the election period cannot be extended until the first taxable year following the promulgation of final section 482 regulation, we recommend that the election period at a minimum be extended for an additional taxable year, thereby not requiring a final election before September 15, 1993 (for calendar-year taxpayers). |
| www.findarticles.com /p/articles/mi_m6552/is_n4_44/ai_12596769 (870 words) |