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 94.
4. lappuse
... arms length price . " Even the Wall Street Journal suggested nisstating the underlying issue ) that the Treasury's enforcement approach is sible . " makes this situation truly strange , is that a remedy is at hand . Long ago , tes had ...
... arms length price . " Even the Wall Street Journal suggested nisstating the underlying issue ) that the Treasury's enforcement approach is sible . " makes this situation truly strange , is that a remedy is at hand . Long ago , tes had ...
5. lappuse
... arms length . " Accordingly , the agency dispatches its audito the millions of transactions within these worldwide corpora tors try to adjust the prices to what they would be if the par at arms length - which they are not and have no ...
... arms length . " Accordingly , the agency dispatches its audito the millions of transactions within these worldwide corpora tors try to adjust the prices to what they would be if the par at arms length - which they are not and have no ...
6. lappuse
... arms - length standard possibity vague , " says David Rosenbloom , a tax attorney with Caplin and Dry le and a former Treasury official . Under the formula method there would be less distortion than exists now . Opp nts often cite the ...
... arms - length standard possibity vague , " says David Rosenbloom , a tax attorney with Caplin and Dry le and a former Treasury official . Under the formula method there would be less distortion than exists now . Opp nts often cite the ...
12. lappuse
... arm's length method is ever going to give us the er ent we need , unless we hire a literal army of agents to try t gle these webs of transactions and deter the transfer - pricin Fits out of this country . GANDHI . Well , it is a problem ...
... arm's length method is ever going to give us the er ent we need , unless we hire a literal army of agents to try t gle these webs of transactions and deter the transfer - pricin Fits out of this country . GANDHI . Well , it is a problem ...
14. lappuse
... arm's length ne , where you want to make sure that the comparable uncon- ed transactions are considered to be the norm and the arm's ch transactions would be priced as if they were at arm's length , you would simply have to let these ...
... arm's length ne , where you want to make sure that the comparable uncon- ed transactions are considered to be the norm and the arm's ch transactions would be priced as if they were at arm's length , you would simply have to let these ...
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Bieži izmantoti vārdi un frāzes
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...
227. lappuse - When I use a word," Humpty Dumpty said, in rather a scornful tone, "it means just what I choose it to mean — neither more nor less."3 "The question is," said Alice, "whether you can make words mean so many different things.
82. 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.
310. lappuse - Convention. Any information so exchanged shall be treated as secret and shall not be disclosed to any persons...
45. lappuse - DIRECTOR, TAX POLICY AND ADMINISTRATION ISSUES, GENERAL GOVERNMENT DIVISION, US GENERAL ACCOUNTING OFFICE Mr.
226. lappuse - ... income from the property and business of a controlled taxpayer. The interests controlling a group of controlled taxpayers are assumed to have complete power to cause each controlled taxpayer so to conduct its affairs that its transactions and accounting records truly reflect the taxable income from the property and business of each of the controlled taxpayers.
226. lappuse - In the conduct of its affairs (or, as the case may be, in the particular contract, transaction, arrangement, or other act) dealt with the other member or members of the group at arm's length. It does not mean the income, the...
149. lappuse - ... total deposits or withdrawable accounts of depositors of the taxpayer at the close of such year exceeds the sum of its surplus, undivided profits, and reserves...
226. lappuse - The purpose of section 482 is to place a controlled taxpayer on a tax parity with an uncontrolled taxpayer, by determining, according to the standard of an uncontrolled taxpayer, the true taxable income from the property and business of a controlled taxpayer.
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.