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Advance Pricing Agreements agreement allocation American subsidiaries APAs Beran capital carryback Chairman Committee compete competitive disadvantage complexity Congress countries DaimlerChrysler deferral disclosure dividends domestic double taxation economic effect eign Finance fleet foreign affiliates foreign competitors foreign corporations foreign income foreign investment foreign operations foreign source income foreign subsidiaries foreign tax credits FPHCI hybrid branches imposed income earned income tax industry interest expense Internal Revenue Code investment abroad investors issues legislation Loffredo manufacturing million multinational corporations percent Perlman Professor Mutti profits proposal provisions reduce regulations repatriated result return information Section Senator Moynihan shipping income Subpart F income tax code tax liability tax policy tax rate tax system tax treaty taxable taxpayers tion trade transfer pricing Treasury U.S. companies U.S. corporations U.S. economy U.S. exports U.S. funds U.S. multinationals U.S. parent U.S. tax law U.S. tax system U.S. taxation U.S.-based companies United withholding tax
Page 150 - return information" means— (A) a taxpayer's identity, the nature, source, or amount of his income, payments, receipts, deductions, exemptions, credits, assets, liabilities, net worth, tax liability, tax withheld, deficiencies...
Page 140 - ... and subpart F provisions to make them the exclusive anti-deferral provisions of the Code. For the reasons set forth in this statement, if the foreign personal holding company provisions ultimately are retained, they should be modified this year to apply the PFIC look-through rules (section 1296(c)) in determining whether a foreign corporation is a foreign personal holding company. Explanation of Proposal The foreign personal holding company rules were enacted in 1937 to eliminate the opportunity...
Page 79 - F was first enacted in 1962, the basic intent was to require current US taxation of foreign income of US multinational corporations that was passive in nature. The 1962 law was careful not to subject active financial services business income to current taxation, through a series of detailed carve-outs.
Page 150 - Investigation or processing, or any other data, received by, recorded by, prepared by. furnished to, or collected by the Secretary with respect to a return or with respect to the determination of the existence, or possible existence, of liability (or the amount thereof) of any person under thl
Page 114 - Other countries may rely to a greater degree on government assessment and negotiation between taxpayer and government — traits which may lead to more government intervention in the affairs of its citizens, less even and fair application of the law among all affected citizens and companies, and less certainty and predictability of results in a given transaction. In some other cases, the complexity of the US system may simply be ahead of development along similar lines in other countries — many...
Page 150 - return information" in part, as follows: (A) a taxpayer's identity, the nature, source, or amount of his income, payments, receipts, deductions, exemptions, credits, assets, liabilities, net worth, tax liability, tax withheld, deficiencies, overassessments, or tax payments, whether the taxpayer's return was, is being, or will be examined or subject to other investigation or processing, or any other data, received by, recorded by.
Page 165 - American Chambers of Commerce Abroad, an increasing number of members are engaged in the export and import of both goods and services and have ongoing investment activities. The Chamber favors strengthened international competitiveness and opposes artificial US and foreign barriers to international business. Positions on national issues are developed by a cross section of its members serving on committees, subcommittees and task forces.
Page 80 - American finance and credit companies, banks, securities firms, and insurance companies will be impaired by an "on-again, off-again" system of annual extensions that does not allow for certainty.
Page 102 - The Investment Company Institute is the national association of the American investment company industry. Its membership includes 4,582 open-end investment companies ('mutual funds'), 433 closed-end investment companies and 13 sponsors of unit investment trusts.
Page 106 - US multinationals did not establish affiliates abroad to produce for the local market, they would be too distant to have an effective presence in that market. In addition, companies from other countries would either establish such facilities or increase exports to that market. In effect, it is not really possible to sustain exports to such markets in the long run. On a net basis, it is highly doubtful that US direct investment abroad reduces US exports or displaces US jobs.