 | United States. Customs Court - 1970 - 1152 lapas
...(c) In determining the foreign market value for the purposes of subsection (a) of this section, if it is established to the satisfaction of the Secretary or his delegate that the amount of any difference between the exporter's sales price and the foreign market value (or that the... | |
 | United States - 1965 - 1110 lapas
...disposed of (or redeemed) was issued, that the disposition (or redemption) of the section 306 stock, was not in pursuance of a plan having as one of its...principal purposes the avoidance of Federal income tax. (c) Section 306 stock defined. (1) In general. For purposes of this subchapter, the term "section 306... | |
 | United States - 1965 - 1008 lapas
...(c) In determining the foreign market value for the purposes of subsection (a) of this section, if it is established to the satisfaction of the Secretary or his delegate that the amount of any difference between the exporter's sales price and the foreign market value (or that the... | |
 | United States - 1964 - 1098 lapas
...of paragraph (3) of this subsection shall not apply with respect to any foreign corporation, if it is established to the satisfaction of the Secretary or his delegate that the earnings and profits of such foreign corporation could not have been distributed to United States shareholders... | |
 | 1979 - 350 lapas
...amount of stock in the controlled corporation constituting control within the meaning of section 368(c), and it is established to the satisfaction of the Secretary...stock and securities) in the controlled corporation vu not in pursuance of a plan having as one of its principal purposes the avoidance of Federal income... | |
 | 2001 - 580 lapas
...must be established to the satisfaction of the Commissioner that the retention by the distributing corporation was not in pursuance of a plan having...principal purposes the avoidance of Federal income tax. Ordinarily, the corporate business purpose or purposes for the distribution will require the distribution... | |
 | 1998 - 512 lapas
...must be established to the satisfaction of the Commissioner that the retention by the distributing corporation was not in pursuance of a plan having...principal purposes the avoidance of Federal income tax. Ordinarily, the corporate business purpose or purposes for the distribution will require the distribution... | |
 | 1990 - 590 lapas
...established to the satisfaction of the Commissioner that the distribution, and the disposition or redemption, was not in pursuance of a plan having as one of its...principal purposes the avoidance of Federal income tax. However, in the case of a prior or simultaneous disposition (or redemption) of the stock with respect... | |
 | 1959 - 1584 lapas
...the 'satisf action' of the' Commissioner that the distribution, and the disposition or redemption, was not in pursuance of a plan having as one of its...principal purposes the avoidance of Federal income tax. However, in the case of a prior or simultaneous disposition (or redemption) of the stock with respect... | |
 | 1978 - 952 lapas
...of paragraph (3) of this subsection shall not apply with respect to any foreign corporation, if it Is established to the satisfaction of the Secretary or his delegate that the earnings and profits of such foreign corporation could not have been distributed to United States shareholders... | |
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... it is established to the satisfaction of the Secretary or his delegate that the retention by the distributing corporation of stock (or stock and securities) in the controlled corporation was not In pursuance of a plan having as one of its principal... 
