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IRS Notice Cracks Down on Offshore 'Leasing' Deferred Compensation Arrangements
Internal Revenue Service [IRS] 
[Official Guidance] Apr. 4, 2003
Excerpt: This notice alerts taxpayers and their representatives that the tax benefits purportedly generated by these arrangements are not allowable ... [Typically, the] Taxpayer ... purports to enter into an employment relationship with a foreign corporation ... that is incorporated and managed in a country with which the United States has an income tax convention. Foreign Leasing Corporation purports to lease the right to Taxpayer's services in the United States to a domestic corporation ...
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