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The Essence of U S Tax Reform 110
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1980 Convention 1986 Code Section adjusted allocation alternative minimum tax amount apply arising Article X(6 assets basis book income branch profits tax branch tax Canada Canadian corporation Canadian tax capital gains cent Code Section 337 computing corporate tax cost December 31 deduction depreciation determined disposition distribution dividend earnings and profits effectively connected excess financing FIRPTA foreign corporation foreign tax credit FPHC gain derived income tax individual investment in U.S. issue limitation loss corporation method NOLs noted operating ordinary income overall payments prior law provides purchaser qualified resident rate of tax reduce regulations repeal Report respect result Revenue second-level tax shareholders step-up target corporation tax rates Tax Reform Act Tax Treaty tax-free taxable income taxation taxpayer tion trade or business transaction transitional rules treaty U.S. branch U.S. business U.S. corporation U.S. dollars U.S. real estate U.S. real property U.S. subsidiary U.S. trade Utilities withholding tax