Export Tax Guide for Manufacturers: How to Use a DISC and Other Forms of Corporations to Export and to Operate Abroad More Profitably |
From inside the book
Results 1-3 of 13
Page 3
... transfer price de- termined under the gross receipts method on any given sale of product A of such product line by the related supplier to the DISC which would allocate to the DISC taxable income equal to not more than 3 per cent ( i.e. ...
... transfer price de- termined under the gross receipts method on any given sale of product A of such product line by the related supplier to the DISC which would allocate to the DISC taxable income equal to not more than 3 per cent ( i.e. ...
Page 4
... transfer price or commission . The DISC and its related supplier would ordinarily determine under section 994 and this section the transfer price payable by the DISC ( or the commission payable to the DISC ) for a transaction before the ...
... transfer price or commission . The DISC and its related supplier would ordinarily determine under section 994 and this section the transfer price payable by the DISC ( or the commission payable to the DISC ) for a transaction before the ...
Page 7
... transfer price btween S and T shall be that price which allocates to T the maximum permitted to be received under the intercompany pricing rules of section 994. Thereafter , the 100 units are sold by T for $ 950 . S's cost of goods sold ...
... transfer price btween S and T shall be that price which allocates to T the maximum permitted to be received under the intercompany pricing rules of section 994. Thereafter , the 100 units are sold by T for $ 950 . S's cost of goods sold ...
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