13) The elegance of this rule is illustrated by simple contrast to the general rule contained in the 1992 Regulations, which accomplishes essentially the same result: Except as otherwise provided in this section, a dual consolidated loss of a dual resident corporation cannot offset the taxable income of any domestic affiliate in the taxable year in which the loss is recognized or in any other taxable year, regardless of whether the loss offsets income of another person under the income tax laws of a foreign country and regardless of whether the income that the loss may offset in the foreign country is, has been, or will be subject to tax in the United States.
What does DRC stand for?
DRC stands for Dual Resident Corporation
This definition appears somewhat frequently and is found in the following Acronym Finder categories:
- Business, finance, etc.
See other definitions of DRC
We have 403 other meanings of DRC in our Acronym Attic
- Domaine de la Romanée Conti (French winery; Burgundy, France)
- Dominique Rodgers-Cromartie (football player)
- Don Royal Cleaners (Pittsburgh, PA)
- Dose-Response Curve
- Douay-Rheims Challoner Revision (bible translation)
- Down (Stage) Right Center
- Downtown Revitalization Committee (various locations)
- Dream-Reality Confusion (psychology)
- Drug Regimen Compliance
- Drug Rehabilitation Center
- Dumbarton Rail Corridor (transportation project; California)
- Dust Recovery Collector (various companies)
- Dutch Reformed Church
- Dynamic Range Control (Dolby Digital)
- Dynamic Rate Change
- Dynamic Ride Control (Audi)
- Dynamics Research Corporation
- Deer Run Community Association (Calgary, Alberta, Canada)
- Délégation Régionale au Commerce et à l'Artisanat (French: Regional Delegation for Trade and Crafts)
- Directorate of Research and Civil Affairs (Australia)
Samples in periodicals archive:
Before this provision was enacted, it was possible to "double dip" losses of a dual resident corporation by using the losses to offset the incomes of both the foreign affiliated group and a U.
To make this election, the dual resident corporation or separate entity must not be subject to any "mirror" DCL rule adopted by the foreign country.
It recommended that the rules clarify that a domestic corporation will be considered a dual resident corporation only if it is itself subject to income tax in the foreign country, either directly or because, under foreign law, it is severally liable as a member of a foreign consolidated or combined tax return.
The dual consolidated loss rules apply to domestic corporations that are dual resident corporations (DRC).