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988 transaction activities adjusted basis allocated amount apply apportioned arm's-length attributable branch capital gain computed Contracting controlled corporation's deduction deemed determined DISC distribution dividend domestic corporation earnings and profits effectively connected eign election entity example exchange gain exempt fair market value filed foreign base company foreign corporation foreign country foreign income foreign person foreign tax credit foreign-source income FPHC income functional currency gain or loss gross income gross receipts income tax intangible property interest expense investment liabilities method nonresident alien operations ordinary income partnership passive income payment PFIC purposes qualified received resident section 482 subpart F income tax rate tax return tax treaty taxable income Temp tion trade or business transfer Treas treated U.S. assets U.S. citizen U.S. corporation U.S. dollars U.S. person U.S. real property U.S. shareholder U.S. tax U.S. trade United USCo USRPI withholding tax