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 50.
11. lappuse
... respect tion's proposal for increased penalties , isn't it people are only afraid of penalties to the ex afraid that their tax avoidance might be disclos general feeling that they can involve themselve cated transactions that are not ...
... respect tion's proposal for increased penalties , isn't it people are only afraid of penalties to the ex afraid that their tax avoidance might be disclos general feeling that they can involve themselve cated transactions that are not ...
12. lappuse
... respect to inte economic units operating on the international level ? GANDHI . I think there is some promise in that . Nevertheless the success of the State level should not be taken as an en ment that it will work at the international ...
... respect to inte economic units operating on the international level ? GANDHI . I think there is some promise in that . Nevertheless the success of the State level should not be taken as an en ment that it will work at the international ...
22. lappuse
... respect e applicability of that formula . Yes , there is . The Container oration case in 1983 sustained that three - factor formula as the mark by which all these questions should be measured . w , when you look at the unitary method ...
... respect e applicability of that formula . Yes , there is . The Container oration case in 1983 sustained that three - factor formula as the mark by which all these questions should be measured . w , when you look at the unitary method ...
23. lappuse
... respect ntainer as the ly only amount to Cali- › corpo- ay us a appor- volved , ɔns , be- ently verified and sustainable . Thereafter , once we have those seven numbe matter of mathematical calculation to determine should be assigned to ...
... respect ntainer as the ly only amount to Cali- › corpo- ay us a appor- volved , ɔns , be- ently verified and sustainable . Thereafter , once we have those seven numbe matter of mathematical calculation to determine should be assigned to ...
24. lappuse
... respect to inose urns , the Franchise Tax Board did not accept those returns . ere was a very good reason we did not accept those . Those ac- nted for the results of a single corporation and all of its particu- subsidiaries , but those ...
... respect to inose urns , the Franchise Tax Board did not accept those returns . ere was a very good reason we did not accept those . Those ac- nted for the results of a single corporation and all of its particu- subsidiaries , but those ...
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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...
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.