Export Tax Guide for Manufacturers: How to Use a DISC and Other Forms of Corporations to Export and to Operate Abroad More Profitably |
Contents
Corporation to Pay Taxes at a Lower Rate | 84 |
U S Possessions | 94 |
Foreign Exchange Fluctuations | 118 |
3 other sections not shown
Common terms and phrases
accumulated DISC income actual distribution adjusted basis apply apportioned buyer combined taxable income computed consent controlled group December 31 deductions deemed distribution deficiency distribution defined in section definitely related described in paragraph determined DISC or former dividend earnings and profits example export promotion expenses export property export sales export trade corporation fair market value filed foreign corporation foreign currency foreign income taxes foreign tax credit former DISC gross receipts income from sources Internal Revenue Code Internal Revenue Service manufacturer's Marginal Costing paid previously taxed income producer's loans proposed in 37 proposed Reg Proposed Treasury Decision Puerto Rico purchaser purposes pursuant qualified export assets qualified export receipts related supplier respect rules safe-haven sale or lease section 482 section 994 selling shareholder shares statutory grouping subdivision subsidiary taxpayer tion Total transaction transfer price treated U.S. corporation U.S. dollars U.S. income tax U.S. manufacturer U.S. tax United WHTC