U.S. International Taxation: Cases and Materials |
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accumulated profits active agreement allocation amount apply Article assets bank base company sales Basle branch Brinco Brown Cayman Brown Group business income capital Commissioner commissions company sales income Congress Contracting controlled foreign corporation deductions deferral determined DISA dividends double taxation Drew Ameroid earned economic effectively connected entity foreign base company foreign source income foreign tax credit Fortress Goodyear gross income imposed income from sources Income Tax Regs interest Internal Revenue Code investment issue jurisdiction letter of credit limitation loan Navios nonresident alien NOTES AND QUESTIONS Nutley operations paragraph partner partnership passive income payments percent permanent establishment petitioner petitioner's plaintiff provisions purchase purposes received regulations related person resale resident respect respondent royalties Smidas statute subpart F income tax haven tax rate tax treaty taxable income taxes paid taxpayer Tensia tion trade or business Treasury U.S. source U.S. tax United Kingdom withholding tax