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 23.
8. lappuse
... examination findings . A staffing model to help allocat international resources has not been adopted yet , and a ne system to capture all examination findings is not yet in plac ird , the IRS has moved toward using different tools ...
... examination findings . A staffing model to help allocat international resources has not been adopted yet , and a ne system to capture all examination findings is not yet in plac ird , the IRS has moved toward using different tools ...
9. lappuse
... examination dat implemented a model to better assess its in needs . However , in its enforcement efforts , IRS has grees certain new and existing procedural tools summonses , advance pricing agreements and For most of them , we found ...
... examination dat implemented a model to better assess its in needs . However , in its enforcement efforts , IRS has grees certain new and existing procedural tools summonses , advance pricing agreements and For most of them , we found ...
46. lappuse
... examination findings from previous years through the appeals process and the courts . fer prices are prices companies charge other related companies for goods rvices transferred on an intercompany basis . - Тах arbitration , but because ...
... examination findings from previous years through the appeals process and the courts . fer prices are prices companies charge other related companies for goods rvices transferred on an intercompany basis . - Тах arbitration , but because ...
51. lappuse
... PRICING IN EXAMINATIONS , APPEALS , AND LITIGATION IRS examiners continue to propose substantial sec adjustments to income . However , IRS appeals offi 1330CD uses audits to encourage corporations to comply with section 6.
... PRICING IN EXAMINATIONS , APPEALS , AND LITIGATION IRS examiners continue to propose substantial sec adjustments to income . However , IRS appeals offi 1330CD uses audits to encourage corporations to comply with section 6.
52. lappuse
... examinations of 47,000 corporations . " amount of proposed adjustments to income that IRS has ntified in audits is in the billions of dollars . For example , 1992 , for cases with total proposed adjustments of $ 20 million more , IRS ...
... examinations of 47,000 corporations . " amount of proposed adjustments to income that IRS has ntified in audits is in the billions of dollars . For example , 1992 , for cases with total proposed adjustments of $ 20 million more , IRS ...
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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
Populāri fragmenti
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.