The Breakdown of IRS Tax Enforcement Regarding Multinational Corporations: Revenue Losses, Excessive Litigation, and Unfair Burdens for U.S. Producers : Hearing Before the Committee on Governmental Affairs, United States Senate, One Hundred Third Congress, First Session, March 25, 1993U.S. Government Printing Office, 1993 - 341 lappuses |
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1.–5. rezultāts no 72.
1. lappuse
... Court down the street . There in roo see the debris from the nation's current multina ment system . One recent case is a good example . It occupie of legal and economic arcana that took 10 year tune to produce . The judge in the case ...
... Court down the street . There in roo see the debris from the nation's current multina ment system . One recent case is a good example . It occupie of legal and economic arcana that took 10 year tune to produce . The judge in the case ...
3. lappuse
... Court down the street . There , in room G - 24 , you can see th tion's current multinational tax enforcement system . One recent case is a good example . It occupies 19 file boxe nomic arcana that took ten years and a small fortune to ...
... Court down the street . There , in room G - 24 , you can see th tion's current multinational tax enforcement system . One recent case is a good example . It occupies 19 file boxe nomic arcana that took ten years and a small fortune to ...
4. lappuse
... court at an increasing rate . ces Zuniga , a former IRS examiner , says in written testimony that " no one lly determine an arms length price . " Even the Wall Street Journal suggested nisstating the underlying issue ) that the ...
... court at an increasing rate . ces Zuniga , a former IRS examiner , says in written testimony that " no one lly determine an arms length price . " Even the Wall Street Journal suggested nisstating the underlying issue ) that the ...
6. lappuse
... court in increasing numbers to appeal the agency's assessments . At la unt there was some $ 32 billion at issue in pending tax court cases alone , not eve unting the cases in the agency's appeals pipeline . " The arms - length standard ...
... court in increasing numbers to appeal the agency's assessments . At la unt there was some $ 32 billion at issue in pending tax court cases alone , not eve unting the cases in the agency's appeals pipeline . " The arms - length standard ...
7. lappuse
... Court . They've also worked out ways to handle foreign ac anyway , this problem is diminishing through the efforts of the tion of Accountants . " Of course the formula method will not yield perfect results Michael J. McIntyre ...
... Court . They've also worked out ways to handle foreign ac anyway , this problem is diminishing through the efforts of the tion of Accountants . " Of course the formula method will not yield perfect results Michael J. McIntyre ...
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adjustments administration advance pricing agreements agreement allocation American amount apply approach arm's arm's-length pricing assets audit billion case-by-case Clinton Committee comparable compliance Cong CONGRESS THE LIBRARY costs countries court depreciation determining dollars double taxation economic enforcement federal firms foreign companies foreign corporations foreign tax foreign-controlled corporations formula formulary apportionment GANDHI income tax industry intercompany Internal Revenue Internal Revenue Service international business issue J.J. Pickle Japan Japanese keiretsu length pricing LIBRARY OF CONGRESS litigation ment method multinational multinational corporations operations penalty percent profits receipts related parties RESS RICO section 482 Senator DORGAN Service source rules standard supra note tax avoidance tax evasion tax law Tax Notes tax returns tax treaties taxable income taxes paid taxpayer terrorem tion trade transfer pricing transfer-pricing Treas U.S. corporations U.S. income U.S. tax U.S. Treasury Department U.S.-controlled corporations United valuation Wickham
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168. lappuse - Where a) an enterprise of a Contracting State participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State, or b) the same persons participate directly or indirectly in the management, control or capital of an enterprise of a Contracting State and an enterprise of the other Contracting State...
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226. lappuse - The standard to be applied in every case is that of an uncontrolled taxpayer dealing at arm's length with another uncontrolled taxpayer.