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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861 regulations abroad allocated to foreign allocation and apportionment allocation of R&D allowed amount apportioned Arthur Andersen Chairman RANGEL CHAPOTON Committee Congress cost deduction disincentive dividends domestic and foreign domestic R&D effect eign ERTA excess credit position excess foreign tax expense to foreign foreign affiliates foreign corporation foreign countries foreign income foreign R&D foreign source income foreign source taxable foreign subsidiary foreign tax credit gross income HEFTEL impact income tax increase incurred industry interest expense Internal Revenue Code Internal Revenue Service investment issue manufacturing million moratorium multinational overseas productiv profits R&D allocation R&D expenditures R&D expense R&D spending research and development research expense royalty section 861 source taxable income Subcommittee tax credit limitation tax policy tax treaties taxation taxes paid tion Treasury Department Treasury Regulation 1.861-8 U.S. and foreign U.S. companies U.S. corporations U.S. firms U.S. source income U.S. tax liabilities U.S. taxpayer United worldwide