Present Law and Certain Issues Relating to Transfer Pricing (code Section 482): Scheduled for Hearings Before the Subcommittee on Oversight of the House Committee on Ways and Means on July 10 and 12, 1990U.S. Government Printing Office, 1990 - 33 lappuses |
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1.5. rezultāts no 16.
4. lappuse
... income that is properly the income of a U.S. entity subject to U.S. taxing juris- diction , when it appears that an ... allocate additional income to the U.S. might theoretically subject a taxpayer to double tax- ation , if both ...
... income that is properly the income of a U.S. entity subject to U.S. taxing juris- diction , when it appears that an ... allocate additional income to the U.S. might theoretically subject a taxpayer to double tax- ation , if both ...
5. lappuse
... income . 6 The statute does not generally prescribe any specific reallocation rules that must be followed , other ... allocate gross income , deductions , credits , or allowances between or among such organizations , trades , or ...
... income . 6 The statute does not generally prescribe any specific reallocation rules that must be followed , other ... allocate gross income , deductions , credits , or allowances between or among such organizations , trades , or ...
6. lappuse
... income or deductions have been shifted between persons in an arbitrary manner . 15 Section 482 invoked only by the IRS Section 482 provides that the Secretary may distribute , appor- tion , or allocate items that are germane to the ...
... income or deductions have been shifted between persons in an arbitrary manner . 15 Section 482 invoked only by the IRS Section 482 provides that the Secretary may distribute , appor- tion , or allocate items that are germane to the ...
12. lappuse
... allocation to services is made.26 Use and transfer of intangibles Intangibles may be transferred , or permitted to ... income allocation standard under which the income of the transfer- or with respect to such transfers or licenses ...
... allocation to services is made.26 Use and transfer of intangibles Intangibles may be transferred , or permitted to ... income allocation standard under which the income of the transfer- or with respect to such transfers or licenses ...
18. lappuse
... allocation by the government of a treaty country of income , deductions , credits , or allowances be- tween persons ... taxes or clearly to reflect the income of any of such persons . The distribution , apportionment , or ...
... allocation by the government of a treaty country of income , deductions , credits , or allowances be- tween persons ... taxes or clearly to reflect the income of any of such persons . The distribution , apportionment , or ...
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adjustments affiliates allocate income apply arm's length method arm's length price arm's length standard buyer reseller charged Code comparable uncontrolled price Cong cost plus method DAN ROSTENKOWSKI determines an arm's distributor double taxation economic equity firms foreign corporation foreign parent foreign person formulary method H.R. Rept inbound income tax income to assets Internal Revenue Service involving issues legislative history loans or advances markup multinational enterprise OECD procedural rates of return ratio of income reallocation regulations provide relevant reportable transactions resale price method rules safe harbors Secretary section 482 service of process summons tangible property tax liability Tax Notes tax treaties taxable income taxpayer tion Toyota Motor Corp trade or business transfer of tangible Treas Treasury Department treaty country U.S. competent authority U.S. corporation U.S. entity U.S. model U.S. subsidiary U.S. tax uncontrolled price method United unrelated party transactions White Paper
Populāri fragmenti
5. lappuse - Secretary or his delegate may distribute, apportion, or allocate gross Income, deductions, credits, or allowances between or among such organizations, trades, or businesses, if he determines that such distribution, apportionment, or allocation is necessary In order to prevent evasion of taxes or clearly to reflect...
14. lappuse - Secretary or his delegate at a time and place named in the summons and to produce such books, papers, records, or other data, and to give such testimony, under oath, as may be relevant or material to such inquiry ; and (3) To take such testimony of the person concerned, under oath, as may be relevant to such inquiry.
18. lappuse - State, and in either case conditions are made or imposed between the two enterprises in their commercial or financial relations which differ from those which would be made between independent enterprises, then any profits which would, but for those conditions have accrued to one of the enterprises, but by reason of those conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly.
14. lappuse - To examine any books, papers, records or other data which may be relevant or material to such inquiry; (2) To summon the person liable for tax or required to perform the act. or any officer or employee of such person, or any person having possession, custody, or care of books of account containing entries relating to the business of the person liable for tax...
18. lappuse - Commissioner is authorized to distribute, apportion, or allocate gross income, deductions, credits, or allowances between or among such organizations, trades, or businesses, if he determines that such distribution, apportionment, or allocation is necessary in order to prevent evasion of taxes or clearly to reflect the income of any of such organizations, trades, or businesses.
12. lappuse - If the creditor was not regularly engaged in the business of making loans or advances of the same general type as the loan or advance in question to unrelated parties, the arm's length rate for purposes of this paragraph shall be (i) The rate of interest actually charged if at least 4 but not in excess of 6 percent per annum simple interest, (ii) 5 percent per annum simple interest if no interest was charged...
14. lappuse - For the purpose of ascertaining the correctness of any return, making a return where none has been made, determining the liability of any person for any internal revenue tax or the liability at law or in equity of any transferee or fiduciary of any person in respect of any internal revenue tax, or collecting any such liability...
13. lappuse - Indebtedness arising in the ordinary course of business out of sales, leases, or the rendition of services by or between members of the group, or any other similar extension of credit.
5. lappuse - organization" includes any organization of any kind, whether it be a sole proprietorship, a partnership, a trust, an estate, an association, or a corporation (as each is defined or understood in the Internal Revenue Code or the regulations...
4. lappuse - Income or deductions between or among them, as may be necessary in order to prevent evasion (by the shifting of profits, the making of fictitious sales, and other methods frequently adopted for the purpose of "milking"), and in order clearly to reflect their true tax liability.