Selected papers (and a few outlines) of panelists at September and December 1971 public technical meetings on DISC, intercompany pricing, foreign exchange, compensating U.S. executives abroad and other current tax problems
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Intercompany Pricing of Sales to a DISC
DISC Rules on Constructive Dividends
Computing the Penalty if any for Investment
15 other sections not shown
abroad affiliate aircraft or vessel allocated amount basis before-tax income Canadian dollars capital gains captive captive insurance charged client computation cost Court currently taxable death tax decedent decedent's deduction deemed distribution deferred devaluation loss DISC election DISC income DISC'S dividend domestic domicile domiciliary earnings English estate duty estate plan estate tax Example expatriate Export Promotion Expenses export property foreign corporation foreign country foreign income foreign investment attributable foreign sales subsidiary foreign source foreign tax credit foreign trust funds gross income gross receipts income tax inter vivos trust interest jurisdiction lease limitation operating ordinary income paid parent payment person premiums probate producer's loans profit provisions qualified export receipts regulations residence Revenue rules safe-haven Section shareholders sold Subpart F tax treaties tax-free taxable income taxation taxpayer tion transaction transferred treated U.S. dollars U.S. income U.S. manufacturer U.S. tax United Kingdom