Internal Revenue Cumulative BulletinDepartment of the Treasury, Internal Revenue Service, 1977 |
No grāmatas satura
1.–5. rezultāts no 85.
33. lappuse
... allocated a portion of its stock basis in the old corporation to the unharvested cotton crop and land preparation pursuant to section 334 ( b ) ( 2 ) of the Code . The new corporation harvested the cotton crop and planted and harvested ...
... allocated a portion of its stock basis in the old corporation to the unharvested cotton crop and land preparation pursuant to section 334 ( b ) ( 2 ) of the Code . The new corporation harvested the cotton crop and planted and harvested ...
45. lappuse
... allocated 1 , 000x shares of the new corporation ' s com - mon stock . The reorganization plan will not be put into effect unless and until it is approved by X ' s creditors and stockholders . Under Section 167 of the Bank - ruptcy Act ...
... allocated 1 , 000x shares of the new corporation ' s com - mon stock . The reorganization plan will not be put into effect unless and until it is approved by X ' s creditors and stockholders . Under Section 167 of the Bank - ruptcy Act ...
46. lappuse
... allocated stock in any reorganized entity . Stock in a corporation under going reorganization to provide for a new company with a sound financial basis cannot be assumed to be worthless where the stockholders are likely to be ...
... allocated stock in any reorganized entity . Stock in a corporation under going reorganization to provide for a new company with a sound financial basis cannot be assumed to be worthless where the stockholders are likely to be ...
50. lappuse
... allocation of the geological and geophysical exploration expenditures on an acreage basis to all the lands on which the taxpayer held an option to explore and lease . Exploration expenditures are capital in nature and should be allocated ...
... allocation of the geological and geophysical exploration expenditures on an acreage basis to all the lands on which the taxpayer held an option to explore and lease . Exploration expenditures are capital in nature and should be allocated ...
51. lappuse
... allocated . ment was to clarify the present regula - property demolishes the buildings Accordingly , the Service will not tions with respect to the proper income situated thereon pursuant to a lease follow the decision of the court in ...
... allocated . ment was to clarify the present regula - property demolishes the buildings Accordingly , the Service will not tions with respect to the proper income situated thereon pursuant to a lease follow the decision of the court in ...
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activities addition agreement allocated allowed amended amount annuity apply apportioned assets authority basis benefits claim computed considered contained Contracting contributions corporation cost Court deduction defined described determined distribution dividends earned effect election employee establishment example exclusion exemption expenses facts Federal filed foreign fund gain gross income grouping imposed income tax individual interest Internal Revenue Internal Revenue Code investment issue less limitation loss manufacturer meaning ment method Office operating organization paid paragraph participant payment percent performed period person portion preparer prior profits provides purchase pursuant qualified reason received regulations requested reserves resident respect result retirement Revenue Code rules Service share shareholders sources statutory taxable taxpayer term tion transfer treated trust United vehicle vides
Populāri fragmenti
402. 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.
53. lappuse - The fair market value is the price at which the property would change hands between a willing buyer and a willing seller, neither being under any compulsion to buy or sell and both having reasonable knowledge of relevant facts.
255. lappuse - ... for his life or for any period not ascertainable without reference to his death or for any period which does not in fact end before his death(1) The possession or enjoyment of, or the right to the income from, the property, or (2) The right, either alone or in conjunction with any person, to designate the persons who shall possess or enjoy the property or the income therefrom.
406. lappuse - States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority...
401. lappuse - The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.
86. lappuse - No gain or loss shall be recognized If property is transferred to a corporation by one or more persons solely In exchange for stock or securities in such corporation, and Immediately after the exchange such person or persons are in control of the corporation...
414. lappuse - Where, however, the person paying the interest, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment...
153. lappuse - In the case of oil and gas wells the allowance for depletion under section 23 (m) shall be 27 y2 per centum of the gross Income from the property during the taxable year, excluding from such gross income an amount equal to any rents or royalties paid or Incurred by the taxpayer In respect of the property.
11. lappuse - Is used as an integral part of manufacturing, production, or extraction or of furnishing transportation, communications, electrical energy, gas, water, or sewage disposal services, or...
232. lappuse - In the case of any loss claimed to have been sustained from any sale or other disposition of shares of stock or securities where it appears that, within a period beginning 30 days before the date of such sale or disposition and ending 30 days after such date...