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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6.–10. rezultāts no 100.
8. lappuse
... issue continued to be difficult and dollar amounts at stake have r ed in the billions . IRS examiners have increased their audit reign controlled corporations , but IRS has not yet succeeded i ining examination findings . A staffing ...
... issue continued to be difficult and dollar amounts at stake have r ed in the billions . IRS examiners have increased their audit reign controlled corporations , but IRS has not yet succeeded i ining examination findings . A staffing ...
9. lappuse
... issues ke have re- their audits ucceeded in elp allocate and a new et in place . ols , such as use of IRS ' what their main in the nuing prob- e the poten- rm's length new regula- still require on and use see in the 90 , about 72 J.S. ...
... issues ke have re- their audits ucceeded in elp allocate and a new et in place . ols , such as use of IRS ' what their main in the nuing prob- e the poten- rm's length new regula- still require on and use see in the 90 , about 72 J.S. ...
10. lappuse
... issues , I think re not yet prepared to testify to them . ar testimony is most interesting , Mr. Gandhi . Let me ask on . You indicate that 72 percent of foreign corporations doin ess in this country pay no Federal income taxes . GANDHI ...
... issues , I think re not yet prepared to testify to them . ar testimony is most interesting , Mr. Gandhi . Let me ask on . You indicate that 72 percent of foreign corporations doin ess in this country pay no Federal income taxes . GANDHI ...
11. lappuse
... issue e among the mini- e process with re- leal with nsaction , is a little egulations of contemporaneous documentation that they v ment their transfer pricing practices . The question here is what incentives the co that . Well , under ...
... issue e among the mini- e process with re- leal with nsaction , is a little egulations of contemporaneous documentation that they v ment their transfer pricing practices . The question here is what incentives the co that . Well , under ...
15. lappuse
... issue , bec folks didn't want the States to have a device b achieve the right amount of tax payments from ness in the States , and that formula survives & workable and upheld by the courts . Senator LEVIN . That was my understanding ...
... issue , bec folks didn't want the States to have a device b achieve the right amount of tax payments from ness in the States , and that formula survives & workable and upheld by the courts . Senator LEVIN . That was my understanding ...
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Bieži izmantoti vārdi un frāzes
adjustments administration advance pricing agreements agreement allocation American amount apply approach arm's arm's-length pricing assets audit billion case-by-case Clinton Committee comparable compliance Cong CONGRESS THE LIBRARY costs countries court depreciation determining dollars double taxation economic enforcement federal firms foreign companies foreign corporations foreign tax foreign-controlled corporations formula formulary apportionment GANDHI income tax industry intercompany Internal Revenue Internal Revenue Service international business issue J.J. Pickle Japan Japanese keiretsu length pricing LIBRARY OF CONGRESS litigation ment method multinational multinational corporations operations penalty percent profits receipts related parties RESS RICO section 482 Senator DORGAN Service source rules standard supra note tax avoidance tax evasion tax law Tax Notes tax returns tax treaties taxable income taxes paid taxpayer terrorem tion trade transfer pricing transfer-pricing Treas U.S. corporations U.S. income U.S. tax U.S. Treasury Department U.S.-controlled corporations United valuation Wickham
Populāri fragmenti
168. 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...
227. 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.
82. 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.
310. lappuse - Convention. Any information so exchanged shall be treated as secret and shall not be disclosed to any persons...
45. lappuse - DIRECTOR, TAX POLICY AND ADMINISTRATION ISSUES, GENERAL GOVERNMENT DIVISION, US GENERAL ACCOUNTING OFFICE Mr.
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226. lappuse - In the conduct of its affairs (or, as the case may be, in the particular contract, transaction, arrangement, or other act) dealt with the other member or members of the group at arm's length. It does not mean the income, the...
149. 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...
226. 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.
226. lappuse - The standard to be applied in every case is that of an uncontrolled taxpayer dealing at arm's length with another uncontrolled taxpayer.