 In any case of two or more organizations, trades, or businesses (whether or not incorporated, whether or not organized in the United States, and whether or not affiliated) owned or controlled directly or indirectly by the same interests, the Secretary...  Reports of the United States Tax Court - 594. lappuseautors: United States. Tax Court - 1970Pilnskats - Par šo grāmatu
 | 1972 - 580 lapas
...provide the following information: (1) The name and address of such person; (2) If such person is one of two or more organizations, trades, or businesses...affiliated) owned or controlled directly or indirectly by the same interests within the meaning of section 482 and the regulations thereunder — (i) The name... | |
 | United States. Congress. Senate. Committee on Foreign Relations - 1977 - 520 lapas
...Internal Revenue Code to apply the so-called "arms-length test". Section 482 provides as follows : "In any case of two or more organizations, trades...or indirectly by the same interests, the Secretary may distribute, apportion, or allocate gross income, deductions, credits, or allowances between or... | |
 | United States. Tax Court - 1977 - 1216 lapas
...declaration and nature of the dividend was controlled by the petitioner. There was a ready market for the affiliated) owned or controlled directly or indirectly by the same interests, the Secretary may distribute, apportion, or allocate gross income, deductions, credits, or allowances between or... | |
 | United States. Tax Court - 1978 - 1146 lapas
...empowers the Commissioner to "distribute, 4 SEC. 482. ALLOCATION OF INCOME AND DEDUCTIONS AMONG TAXPAYERS. apportion, or allocate gross income, deductions, credits, or allowances" between or among "two or more organizations, trades, or businesses * * * owned or controlled directly or indirectly... | |
 | 1981 - 28 lapas
...(S. Rep. No. 830, 88th Cong., 2d. Sees. 102) B. Present Law Section 482 Section 482 provides that — In any case of two or more organizations, trades,...or indirectly by the same interests, the Secretary may distribute, apportion, or allocate gross income, deductions, credits, or allowances between or... | |
 | United States. Congress. Joint Committee on Taxation - 1985 - 36 lapas
...Allocation of income and deductions among related taxpayers The Secretary of the Treasury is authorized to apportion or allocate gross income, deductions, credits, or allowances, between or among related taxpayers (including corporations), if such action is necessary to prevent evasion of tax or... | |
 | United States. Supreme Court, John Chandler Bancroft Davis, Henry Putzel, Henry C. Lind, Frank D. Wagner - 1986 - 1316 lapas
...in their formal ledgers. Thus, for example, 26 USC §482 provides: "In any case of two or more . . . businesses (whether or not incorporated, whether or...or indirectly by the same interests, the Secretary [of the Treasury] may distribute, apportion, or allocate gross income, deductions, credits, or allowances... | |
 | 1987 - 1412 lapas
...Allocation of income and deduction* among related taxpayers The Secretary of the Treasury was authorized to apportion or allocate gross income, deductions, credits, or allowances, between or among related taxpayers (including corporations), if such action was necessary to prevent evasion of tax... | |
 | 1988 - 980 lapas
...payments between controlled parties do not meet this arm's-length test, under Code $ 482 the Service is to distribute, apportion, or allocate gross income, deductions, credits, or allowances between or among such commonlycontrolled organizations, trades, or businesses "in order to prevent evasion or clearly to... | |
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