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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861-8 regulations abroad allocated to foreign allocation and apportionment allocation of R&D allocation rules allowed amount apportioned Arthur Andersen Chairman RANGEL CHAPOTON Congress 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 countries 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 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 Department 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
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86. lappuse - be claimed for income, war profits, and excess profits taxes paid or accrued during the taxable year to any foreign country or to any
155. lappuse - Chemicals and allied products (29) Petroleum refining and related industries (30) Rubber and miscellaneous plastics products (31) Leather and leather products (32) Stone, clay, glass, and concrete products (33) Primary metal industries. (34) Fabricated metal
86. lappuse - country or possession has in force a general income tax law; (2) the corporation claiming the credit would, in the absence of a specific provision applicable to the corporation, be subject to the general income tax; and (3) the general income tax is not imposed on the
89. lappuse - expenses, losses, and other deductions which cannot definitely be allocated to some item or class of gross income shall be deducted from
155. lappuse - 59) Retail trade (not applicable with respect to sales by the taxpayer of goods and services from any other of the taxpayer's product categories, except Wholesale trade, and not applicable with respect to a domestic international sales corporation for which the taxpayer is a related supplier of goods and services
155. lappuse - Communication (49) Electric, gas. and sanitary services (50, 51) Wholesale trade (not applicable with respect to sales by the taxpayer of goods and services from any other of the taxpayer's product categories and not applicable with respect to a domestic international sales corporation tor which the taxpayer is a related
90. lappuse - satisfaction, treat any dividends which are paid in the first 60 days of any taxable year as having been paid from the accumulated profits of the preceding
248. lappuse - be allocated to foreign source income. Foreign governments do not recognize this allocation as a deduction in computing their income tax. The effect, as noted in the Treasury Department's June 1983 report on "The Impact of the Section 861-8 Regulation on US Research and Development," is to increase the over-all US plus foreign tax, liability of US companies engaged in research
138. lappuse - I am a Professor of Law at the New York University School of Law, 40 Washington Square South, New York, New York 10012.
87. lappuse - income. The amount of any income, war profits, and excess profits taxes paid or accrued, or deemed paid