Search

Your search keyword '"Controlled foreign corporations -- Taxation"' showing total 792 results
Start Over Descriptor "Controlled foreign corporations -- Taxation"
792 results on '"Controlled foreign corporations -- Taxation"'

153. IRS throws the book at s. 936 exits.

Author

Aud, Ernest F., Benson, David M., and Gordon, Murray L.

Subjects
Foreign tax credit -- Laws, regulations and rules, Controlled foreign corporations -- Taxation, Government regulation, Internal Revenue Code (I.R.C. 936), Internal Revenue Code (I.R.C. 367(d))
Published
2008

154. And you thought the branch rule was complicated before: the impact of the proposed contract manufacturing regulations.

Author

Fuller, James P., Halpern, Adam S., Fitzgibbon, Timothy J., and Neumann, Larissa B.

Subjects
Contract manufacturing -- Laws, regulations and rules, Controlled foreign corporations -- Taxation, Foreign source income taxation -- Laws, regulations and rules, Government regulation, Internal Revenue Code (I.R.C. 954(d)(1))
Abstract

Introduction On February 28, 2008, the Treasury Department (the "Treasury") issued proposed regulations (1) with respect to the foreign base company sales income (FBCSI) rules of subpart F. (2) The [...]

Published
2008

155. LTR 200825009: IRS rules that sale of carbon emission allowances did not generate foreign personal holding company income.

Author

McDonald, John D. and Lipeles, Stewart R.

Subjects
Emissions credit trading -- Taxation, Controlled foreign corporations -- Taxation, Personal holding companies -- Taxation, Income tax -- Laws, regulations and rules, Government regulation, Internal Revenue Code (I.R.C. 864)
Abstract

Introduction In our March 2007 column, Kyoto Meets Subpart F: U.S. and Foreign Tax Implications of Structuring for Global Emissions Trading, (1) we discussed the rather recent phenomenon involving the [...]

Published
2008

156. Vodafone 2 v. HMRC: the roaming boundaries of European Community law.

Author

Sykes, Laurent

Subjects
Controlled foreign corporations -- Taxation, Domicile in taxation -- Laws, regulations and rules, Vodaphone 2 v. Commissioners for Her Majesty's Revenue & Customs (2008 E.W.H.C. 1569 (Ch.)), Government regulation, Treaty of Rome, 1957 (art. 43)
Published
2008

159. The treasury releases long-awaited contract manufacturing guidance.

Author

Lipeles, Stewart R. and McDonald, John D.

Subjects
Contract manufacturing -- Taxation, Controlled foreign corporations -- Taxation, Internal Revenue Code (I.R.C. 954)
Abstract

The IRS issued proposed regulations in February addressing contract manufacturing structures and the branch rule ("Proposed Regulations"). (1) These long-awaited Proposed Regulations provide guidance on when a controlled foreign corporation [...]

Published
2008

160. Virtual manufacturing and the proposed contract manufacturing regulations.

Author

Granwell, Alan W. and Andreoli, Brian

Subjects
Contract manufacturing -- Taxation, Controlled foreign corporations -- Taxation, Foreign source income taxation -- Laws, regulations and rules, Government regulation
Abstract

Introduction On February 27, 2008, the Internal Revenue Service issued the long-awaited proposed regulations dealing with whether contract manufacturing arrangements entered into by a controlled foreign corporation (CFC) will constitute [...]

Published
2008

161. TEI's comments on proposed contract manufacturing regulations.

Subjects
Contract manufacturing -- Laws, regulations and rules -- Taxation, Controlled foreign corporations -- Taxation, Foreign source income taxation -- Laws, regulations and rules, Government regulation
Abstract

On June 11, 2008, Tax Executives Institute filed the following comments on the proposed regulations relating to contract manufacturing arrangements under section 954(d) of the Internal Revenue Code. The comments [...]

Published
2008

162. What the proposed contract manufacturing regulations are all about.

Author

McComber, James and Smiley, Stafford

Subjects
Contract manufacturing -- Taxation, Controlled foreign corporations -- Taxation, Foreign source income taxation -- Laws, regulations and rules, Government regulation, Internal Revenue Code (I.R.C. 954)
Published
2008

165. A brave new world - the application of Code sec. 267(a)(3)(B) to expenses accrued by controlled foreign corporations.

Author

Harter, L.G. and Lee, Rebecca E.

Subjects
Controlled foreign corporations -- Taxation, Expense deductions -- Laws, regulations and rules, Government regulation, American Jobs Creation Act of 2004, Internal Revenue Code (I.R.C. 267(a)(3)(B))
Abstract

I. Introduction A fixture of the modern Internal Revenue Code (the "Code") is the prohibition against claiming deductions with respect to amounts owed (or losses realized from transactions) between related [...]

Published
2008

167. Contract manufacturing arrangements and subpart F.

Author

Granwell, Alan W.

Subjects
Contract manufacturing -- Taxation, Controlled foreign corporations -- Taxation, Foreign source income taxation -- Laws, regulations and rules, Government regulation
Published
2008

169. Challenges ahead for contract manufacturing in China.

Author

Kemm, Larry R., Sharp, William M., and Williams, Mark E.

Subjects
Contract manufacturing -- Taxation, Controlled foreign corporations -- Taxation, Corporate income taxes -- Laws, regulations and rules, Government regulation
Published
2008

170. Contract manufacturing: is the war over?

Author

Bates, Stephen R.A. and Kirkwood, Derrick A.

Subjects
Contract manufacturing -- Taxation, Corporate income taxes -- Laws, regulations and rules, Controlled foreign corporations -- Taxation, Government regulation, Internal Revenue Code (I.R.C. 936)
Published
2008

171. Tax-free repatriation transactions under attack again.

Author

Cornett, J. Michael

Subjects
Controlled foreign corporations -- Taxation, Foreign source income taxation -- Laws, regulations and rules, Corporate reorganizations -- Taxation, Government regulation, Internal Revenue Code (I.R.C. 367)
Abstract

Just before the end of 2007, the Internal Revenue Service and the Treasury Department (collectively, the "Government") again "crashed the party" to prevent a "tax-free repatriation" of cash from a [...]

Published
2008

172. Consolidation in the global positioning and navigation industry illustrates tax issues and opportunities in cross-border acquisitions.

Author

Andersen, Richard E.

Subjects
Controlled foreign corporations -- Taxation, Acquisitions and mergers -- Laws, regulations and rules, Government regulation
Abstract

Introduction It never fails: what was once a small corner of a much larger and maturing industry sees a sudden burst of growth, and shortly thereafter the level of merger [...]

Published
2008

173. The egg of Columbus Container: German budget sunny side up, not scrambled.

Author

Kessler, Wolfgang and Eicke, Rolf

Subjects
Partnership -- Taxation, Branch profits tax -- Laws, regulations and rules, Controlled foreign corporations -- Taxation, Columbus Container Services v. Finanzamt Bielefeld-Innenstadt (Case C-298/05 (E.C.J. Dec. 6, 2007)), Government regulation
Published
2008

174. Overview of the French CFC legislation

Author

Gouthiere, Bruno

Subjects
Controlled foreign corporations -- Laws, regulations and rules, Controlled foreign corporations -- Taxation, Tax policy -- Evaluation, Government regulation, Banking, finance and accounting industries, Business, Business, international
Published
2008

176. German CFC rules held compatible with EU law.

Author

O'Shea, Tom

Subjects
Controlled foreign corporations -- Taxation, Foreign source income taxation -- Laws, regulations and rules, Government regulation
Published
2007

177. Controlled foreign corporations in the EU after Cadbury Schwepps.

Author

Malherbe, Jacques, de Mones, Sebastien, Durand, Pierre-Henri, Jacob, Friedhelm, Link, Mathias, Silvestri, Andrea, Brunello, Stefano, Sleurink, Paul, Bondrager, Rens, Lasarte, Guillermo Canalejo, Peydro, Miguel Bastida, Edge, Stephen, and Storey, Oliver

Subjects
Controlled foreign corporations -- Taxation, Foreign source income taxation -- Analysis, Cadbury Schweppes PLC v. Commissioners of Inland Revenue (Case C-196/04 (E.C.J. Sept. 12, 2006))
Published
2007

178. 'Manufacturing' foreign base company sales income.

Author

Chip, William W.

Subjects
Controlled foreign corporations -- Taxation, Foreign source income taxation -- Laws, regulations and rules, Corporate income taxes -- Laws, regulations and rules, Government regulation, Internal Revenue Code (I.R.C. 954(d))
Published
2007

179. New Danish limitations on interest deductions

Author

Bjornholm, Nikolaj and Thiersen, Inger Toft

Subjects
Denmark -- Tax policy, Interest deductions -- Laws, regulations and rules, Tax law -- Interpretation and construction, Corporate income taxes -- Laws, regulations and rules, Controlled foreign corporations -- Taxation, Tax law, Government regulation, Banking, finance and accounting industries, Business, Business, international
Published
2007

180. The substantial assistance rules: an evolution in subpart F planning.

Author

Anson, Tim, Dubert, Carl, and Chen, Matthew

Subjects
Taxation of services -- Laws, regulations and rules, Foreign source income taxation -- Laws, regulations and rules, Controlled foreign corporations -- Taxation, Government regulation, Internal Revenue Code (I.R.C. 954)
Published
2007

181. Charitable remainder trusts and passive foreign investment companies: a modest proposal.

Author

Peebles, Laura H.

Subjects
Charitable remainder trusts -- Taxation, Passive activity (Taxation) -- Laws, regulations and rules, Foreign investments -- Taxation, Investment companies -- Taxation, Controlled foreign corporations -- Taxation, Government regulation, Internal Revenue Code (I.R.C. 1291), Internal Revenue Code (I.R.C. 664), Internal Revenue Code (I.R.C. 512-514)
Published
2007

182. Applying recent Code section 165(g)(3) guidance in an international context.

Author

McHoney, Douglas L. and Cornett, J. Michael

Subjects
Tax planning -- Laws, regulations and rules, Controlled foreign corporations -- Taxation, Loss deductions -- Laws, regulations and rules, Dividends -- Taxation, Government regulation, Company dividends, Internal Revenue Code (I.R.C. 165(g)(3))
Abstract

When determining the optimal structure for investing in foreign subsidiaries, international tax professionals must consider many factors from both a business and tax perspective. These factors include weighing the advantages [...]

Published
2007

185. Tiered CFCs and inbound exchanges.

Author

Kysar, Rebecca M.

Subjects
Controlled foreign corporations -- Taxation, Foreign source income taxation -- Laws, regulations and rules, Government regulation, Internal Revenue Code (I.R.C. 367(b)), Internal Revenue Code (I.R.C. 1248)
Published
2007

186. Controlled foreign companies and foreign profits.

Author

Taylor, David and Sykes, Laurent

Subjects
Controlled foreign corporations -- Taxation, Foreign source income taxation -- Laws, regulations and rules, Government regulation, United Kingdom. Finance Act 2007 (s. 48)
Published
2007

188. Killing off the Killer B.

Author

Sheppard, Lee A.

Subjects
Corporate reorganizations -- Taxation, Controlled foreign corporations -- Taxation, Internal Revenue Code (I.R.C. 956), Internal Revenue Code (I.R.C. 951)
Published
2007

189. Intragroup transactions: the kinder, gentler subpart F.

Author

Braiterman, Andrew H.

Subjects
Controlled foreign corporations -- Taxation, Corporate income taxes -- Laws, regulations and rules, Government regulation, Internal Revenue Code (I.R.C. 954(c)(6))
Published
2007

190. New dual consolidated loss regulations applied to s. 953(d).

Author

Ocasal, Christopher

Subjects
Consolidated tax returns -- Laws, regulations and rules, Loss deductions -- Laws, regulations and rules, Controlled foreign corporations -- Taxation, Government regulation, Internal Revenue Code (I.R.C. 953(d))
Published
2007

191. Congress and Treasury's attack on importing taxpayer-favorable tax attributes.

Author

Calianno, Joseph M. and Spitzenberger, Joseph M.

Subjects
Controlled foreign corporations -- Taxation, Tax elections -- Laws, regulations and rules, Corporate reorganizations -- Taxation, Loss deductions -- Laws, regulations and rules, Government regulation, Internal Revenue Code (I.R.C. 367(b)), Internal Revenue Code (I.R.C. 362)
Published
2007

192. U.K. tax update: shh! You-know-who hasn't started singing yet.

Author

Johnson, Trevor

Subjects
Subsidiary corporations -- Taxation, Controlled foreign corporations -- Taxation, Domicile in taxation -- Laws, regulations and rules, Corporations -- Taxation, Corporations -- Laws, regulations and rules, Cadbury Schweppes PLC v. Commissioners of Inland Revenue (Case C-196/04 (E.C.J. Sept. 12, 2006)), Government regulation
Published
2007

194. IRS takes sound approach to applying CFC look-through rule.

Author

Calianno, Joseph M. and Collins, Martin J.

Subjects
Controlled foreign corporations -- Taxation, Allocation (Taxation) -- Laws, regulations and rules, Foreign source income taxation -- Laws, regulations and rules, Government regulation, Internal Revenue Code (I.R.C. 954(c)(6))
Published
2007

198. CFC look-through: needed clarification, abuses shut down.

Author

Greenwald, Lewis J. and Rubinger, Jeffrey L.

Subjects
Controlled foreign corporations -- Taxation, Foreign source income taxation -- Laws, regulations and rules, Tax elections -- Laws, regulations and rules, Government regulation
Published
2007

200. Qualifying income of a RIC from investment in a CFC.

Author

Collinson, Dale S.

Subjects
Investment companies -- Taxation, Controlled foreign corporations -- Taxation, Corporate income taxes -- Laws, regulations and rules, Government regulation, Internal Revenue Code (I.R.C. 851(b)(2))
Published
2007

Catalog

Books, media, physical & digital resources
See catalog results