Research and Experimental Source Allocation Rules: Hearings Before the Subcommittee on Oversight of the Committee on Ways and Means, House of Representatives, Ninety-eighth Congress, First Session, October 26; November 3, 1983
U.S. Government Printing Office, 1984 - 268 lappuses
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abroad activities additional affiliates allocation allowed American amount applies apportioned apportionment assume basis benefit Chairman RANGEL Code column Committee companies computing conducted Congress corporation cost deduction Department determining domestic R&D earned economic effect encourage ERTA estimate example excess credit fact firms foreign corporation foreign countries foreign income foreign source income foreign tax credit gross income impact important incentive income tax increase incurred industry interest Internal Revenue Code investment issue less liabilities LIBRARY limitation loss manufacturing markets method million moratorium multinational operations overseas paid percent performed present problem profits Proposed Regulation question R&D expense reasons recommendations reduce relative research and development respect result royalty rules section 861 share statement Subcommittee subsidiaries tax policy tax rate taxation taxpayer Thank tion transfer Treasury U.S. tax United worldwide
28. lappuse - States, there shall be deducted (for the purpose of computing the net income therefrom) the expenses, losses and other deductions properly apportioned or allocated thereto and a ratable part of other expenses, losses or other deductions which cannot definitely be allocated to some item or class of gross income.
140. lappuse - New York University School of Law, 40 Washington Square South, New York, New York 10012.
84. lappuse - States and of a domestic corporation, the amount of any income, war profits, and excess profits taxes paid or accrued during the taxable year to any foreign country or to any possession of the United States; and (2) RESIDENT OF THE UNITED STATES OR PUERTO RICO.
173. lappuse - McNeill follows:] STATEMENT OF ROBERT L. McNEILL, EXECUTIVE VICE CHAIRMAN. EMERGENCY COMMITTEE FOR AMERICAN TRADE, BEFORE THE COMMITTEE ON WAYS AND MEANS SUBCOMMITTEE ON TRADE HEARINGS ON COMPREHENSIVE TRADE LEGISLATION Wednesday.
84. lappuse - Such choice for any taxable year may be made or changed at any time before the expiration of the period prescribed for making a claim for credit or refund of the tax imposed by this chapter for such taxable year.
226. lappuse - Where more than one operative section applies. It may be necessary for the taxpayer to apply this section separately for each applicable operative section. In such a case, the taxpayer is required to use the same method of allocation and the same principles of apportionment for all operative sections. (II) When expenses, losses, and other deductions that have been properly allocated and apportioned between combined gross Income of a related supplier and a DISC or former DISC and residual gross Income,...
243. lappuse - ... that findings may contribute unexpected benefits, and that the gross income derived from successful research and development must bear the cost of unsuccessful research and development. Expenditures for research and development which a taxpayer deducts under section 174 shall ordinarily be considered deductions which are definitely related to all income reasonably connected with the relevant broad product category (or categories) of the taxpayer and therefore allocable to all items of gross income...
88. lappuse - ... days of any year as having been paid from the accumulated profits of the preceding year or years (unless to his satisfaction shown otherwise), and in other respects treating dividends as having been paid from the most recently accumulated gains, profits, or earnings.