The Breakdown of IRS Tax Enforcement Regarding Multinational Corporations: Revenue Losses, Excessive Litigation, and Unfair Burdens for U.S. Producers : Hearing Before the Committee on Governmental Affairs, United States Senate, One Hundred Third Congress, First Session, March 25, 1993U.S. Government Printing Office, 1993 - 341 lappuses |
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accounting action activities additional adjustments administration agreement allocation American amount apply apportionment approach arm's length assets audit authorities believe billion California Clinton combined Committee companies comparable Congress controlled corporations costs countries court determining dollars DORGAN economic effect enforcement equipment estimates examination existing fact fair federal firms foreign foreign-controlled formula going hearings income tax increase industry interest international business involved issue Japan Japanese lack less limited loss major Means method multinational officials operations paid parties penalty percent practices present problem profit proposed question reasonable reduce regulations respect result revenue RICO rules section 482 Senator Service share solution standard subsidiaries suggest supra tax returns taxable taxation taxpayers tion trade transactions transfer pricing Treasury treaty United
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143. lappuse - Where: (a) an enterprise of a Contracting State participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State, or (b) the same persons participate directly or indirectly in the management, control or capital of an enterprise of a Contracting State and an enterprise of the other Contracting State...
72. 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.
185. lappuse - When I use a word," Humpty Dumpty said, in rather a scornful tone, "it means just what I choose it to mean — neither more nor less."3 "The question is," said Alice, "whether you can make words mean so many different things.
127. lappuse - ... total deposits or withdrawable accounts of depositors of the taxpayer at the close of such year exceeds the sum of its surplus, undivided profits, and reserves at the beginning of such year (taking into account any portion thereof attributable to the period before the first taxable year beginning after December 31, 1951).
45. lappuse - DIRECTOR, TAX POLICY AND ADMINISTRATION ISSUES, GENERAL GOVERNMENT DIVISION, US GENERAL ACCOUNTING OFFICE Mr.
184. lappuse - ... income from the property and business of a controlled taxpayer. The interests controlling a group of controlled taxpayers are assumed to have complete power to cause each controlled taxpayer so to conduct its affairs that its transactions and accounting records truly reflect the taxable income from the property and business of each of the controlled taxpayers.
249. lappuse - Convention. Any information so exchanged shall be treated as secret and shall not be disclosed to any persons...
184. lappuse - The purpose of section 482 is to place a controlled taxpayer on a tax parity with an uncontrolled taxpayer, by determining, according to the standard of an uncontrolled taxpayer, the true taxable income from the property and business of a controlled taxpayer.
184. lappuse - The standard to be applied in every case is that of an uncontrolled taxpayer dealing at arm's length with another uncontrolled taxpayer.
74. lappuse - Hearing Before the Subcommittee on Oversight of the House Committee on Ways and Means, 102d Cong., 2d Sess.