Analyzing the Constraints of the OECD Corporate Mediation Process
Tax Notes Talk
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Underwar Leases Are Distinguishable From Nuclear Decommissioning Obligations
The Oxford paper doctrine can no longer be relied upon to exclude a cash payment received by the assene of an underwar lease. Section 461H was enacted in 1984 several decades after the Oxford case was decided and then blessed by the IRS. The economic performance rules for underwar leases operate differently from the way those rules operate for nuclear decommissioning obligations.
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