Financing, Tax and Operational Benefits Embedded in Section 883 Regs

During June 2007, the U.S. Treasury Department and the Internal Revenue Service (“IRS”) released temporary and proposed regulations (the “2007 Regulations”) concerning the reciprocal shipping exemption under Section 883 of the Internal Revenue Code. Besides tax benefits, a deeper understanding of certain of the 2007 Regulation’s provisions can provide financing and operational benefits for vertically integrated shippers.

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