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 |
No grāmatas satura
1.–5. rezultāts no 100.
2. lappuse
... result in the witness being denied the opportunity to testify in person . Each statement to be presented to the Subcommittee or any written statement submitted for the printed record must contain the following information : 1. The name ...
... result in the witness being denied the opportunity to testify in person . Each statement to be presented to the Subcommittee or any written statement submitted for the printed record must contain the following information : 1. The name ...
5. lappuse
... results in distortions , because much of the income within the group may be completely unrelated to the expenses involved . So , at the very least this formula should be changed . However , I seriously doubt whether it is ever going to ...
... results in distortions , because much of the income within the group may be completely unrelated to the expenses involved . So , at the very least this formula should be changed . However , I seriously doubt whether it is ever going to ...
11. lappuse
... result , unfair to the companies . It is particularly unfair since several countries - Germany is quite well known in this area - discriminate and do not allow royalties paid to U.S. par- ents to be what arguably is the economic worth ...
... result , unfair to the companies . It is particularly unfair since several countries - Germany is quite well known in this area - discriminate and do not allow royalties paid to U.S. par- ents to be what arguably is the economic worth ...
12. lappuse
... result is still total tax of $ 50 saved although it is not all saved in one country . Basically then unless there are substantial withholding taxes- which would increase the tax on P - a company does not have a tax incentive to go ...
... result is still total tax of $ 50 saved although it is not all saved in one country . Basically then unless there are substantial withholding taxes- which would increase the tax on P - a company does not have a tax incentive to go ...
15. lappuse
... result will be : Foreign taxes U.S. taxes . U.S. income $ 80 Foreign income $ 100 0 50 40 0 If to foreign income : If it had had only the $ 100 of United States source income , its United States tax would have been $ 50 . 2 The ...
... result will be : Foreign taxes U.S. taxes . U.S. income $ 80 Foreign income $ 100 0 50 40 0 If to foreign income : If it had had only the $ 100 of United States source income , its United States tax would have been $ 50 . 2 The ...
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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.