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, 1983U.S. Government Printing Office, 1984 - 268 lappuses |
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1.–5. rezultāts no 53.
1. lappuse
... present moratorium . ) The Subcommittee hearing will ( 1 ) focus on the findings and recommendations contained in Treasury's June 1983 Report , " The Impact of the Section 861-8 Regula- tion on U.S. Research and Development " , and ...
... present moratorium . ) The Subcommittee hearing will ( 1 ) focus on the findings and recommendations contained in Treasury's June 1983 Report , " The Impact of the Section 861-8 Regula- tion on U.S. Research and Development " , and ...
3. lappuse
... present law to make tax free transfers of technology for use in manufacturing operations abroad ; and three , the research activities and location response of taxpayers who are affected by changes in source allocation rules . As I ...
... present law to make tax free transfers of technology for use in manufacturing operations abroad ; and three , the research activities and location response of taxpayers who are affected by changes in source allocation rules . As I ...
9. lappuse
... present any particular point of view and it is not intended to discuss jobs or economic effects . I vol- unteered and intend to explain what the moratorium actually does . I will do so in five steps . The first is what the section 861 ...
... present any particular point of view and it is not intended to discuss jobs or economic effects . I vol- unteered and intend to explain what the moratorium actually does . I will do so in five steps . The first is what the section 861 ...
16. lappuse
... present the same issue : whether income which is economically attributa- ble to the United States is to be exempt from tax . Assume also that the company invests enough in banks to produce $ 20 of interest . If invested in United States ...
... present the same issue : whether income which is economically attributa- ble to the United States is to be exempt from tax . Assume also that the company invests enough in banks to produce $ 20 of interest . If invested in United States ...
18. lappuse
... Present section 861 regulations As adopted in 1977 and as still in effect ( without regard to the statutory moratori- um ) , the section 861 regulations recognized the companies ' arguments - especially the third - by permitting ...
... Present section 861 regulations As adopted in 1977 and as still in effect ( without regard to the statutory moratori- um ) , the section 861 regulations recognized the companies ' arguments - especially the third - by permitting ...
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Bieži izmantoti vārdi un frāzes
abroad allocated to foreign allocation of R&D allocation rules allowed amount apportioned Arthur Andersen Chairman RANGEL CHAPOTON CONGRESS THE LIBRARY deduction disincentive dividends domestic and foreign domestic R&D economic effect eign ERTA excess credit position excess foreign tax expense to foreign foreign affiliates foreign corporation foreign country foreign income foreign R&D foreign source income foreign source taxable foreign subsidiary foreign tax credit foreign tax rate gross income impact income tax increase incurred industry interest expense Internal Revenue Code Internal Revenue Service investment issue LIBRARY OF CONGRESS manufacturing million moratorium multinational overseas Price Waterhouse profits R&D activity R&D allocation R&D expenditures R&D expense R&D spending research and development research expense royalty source taxable income Subcommittee tax credit limitation tax incentives tax policy tax treaties taxation tion Treasury Regulation U.S. and foreign U.S. companies U.S. corporations U.S. income U.S. research U.S. source income U.S. tax liabilities United worldwide
Populāri fragmenti
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.
244. lappuse - Department of the Treasury, The Impact of the Section 861-8 Regulation on US Research and Development (June 1983).
136. lappuse - New York University School of Law, 40 Washington Square South, New York, New York 10012.
80. 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.
171. 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.
80. 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.
222. 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,...
239. 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...
84. 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.
207. lappuse - STATEMENT OF HON. DON J. PEASE, A REPRESENTATIVE IN CONGRESS FROM THE STATE OF OHIO Mr. PEASE. Thank you very much, Mr.