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Income Tax Regulations, As of January 2007 (VOLUME THREE)
by CCH Tax Law Editors
See all pages
with references to "general limitation income".
Excerpt - on Page 552: "
... pays or accrues $40,000 of coun- try X taxes. For purposes of section 904(d), the income from business M is general limitation income and the income from the passive invest- ments is passive income. Pursuant to the part- nership agreement, all partnership items, ... "
Key Phrases:
Internal Revenue Code, Virgin Islands, Puerto Rico, Code Secs, Temporary Reg, Taxable Transfer, general limitation income, foreign base company income, foreign personal holding company income, base company sales income, base company shipping operations, trust sales proceeds
(see more)
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International Income Taxation: Code and Regulations--Selected Sections
by Richard C. Pugh; Charles H. Gustafson; and Robert J. Peroni
See all pages
with references to "general limitation income".
Excerpt - on Page 1342: "
... pays or accrues $40 of country X taxes. For purposes of section 904(d), the in- come from business M is general limitation income and the income from the passive invest- ments is passive income. Pursuant to the part- nership agreement, all partnership items, ... "
Key Phrases:
Income Tax Regulations, Internal Revenue Code, Internal Revenue Service, Puerto Rico, Virgin Islands, Temporary Reg, general limitation income, dual resident corporation, transferee foreign corporation, base company sales income, dual consolidated loss, foreign base company income
(see more)
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Income Tax Regulations, As of January 2007
by CCH Tax Law Editors
See all pages
with references to "general limitation income".
Excerpt - on Page 20: "
... 1000 LCs consisting of 900 LCs of financial services in- come earned by A and 100 LCs (200 DC/2) of general limitation income earned by B. Neither A nor B makes any remittances during 1987. (ii) In 1988, neither A nor B earns ... "
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Income Tax Regulations, As of January 2007 (VOLUME SIX)
by CCH Tax Law Editors
See all pages
with references to "general limitation income".
Excerpt - on Page 642: "
... German Branch has total average assets of Sf1,000,000 which generate income as follows: Sf750,000 of assets that generate foreign source general limitation income under section 904(d)(1)(I), none of which is subpart F income under section 952; and Sf250,000 of assets that generate foreign ... "
Key Phrases:
United States, Treasury Department, Internal Revenue Code, Constitution Avenue, Executive Order, Commissioner of Internal Revenue, dual resident corporation, dual consolidated loss, proposed rulemaking will, regulations proposed herein, global dealing operation, annual benefit attributable
(see more)
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