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Search results for: “internal revenue code”

  • Western Hemisphere Trading Corporation

    A domestic U.S. corporation which was entitled to certain tax advantages under Sections 921-22 of the Internal Revenue Code. To qualify, a U.S.- chartered corporation must (1) derive at least 95 percent of its gross income for the three-year period immediately preceding the taxable year (or througho…

  • Western Hemisphere Trading Corporation

    A domestic U.S. corporation which was entitled to certain tax advantages under Sections 921-22 of the Internal Revenue Code. To qualify, a U.S.- chartered corporation must (1) derive at least 95 percent of its gross income for the three-year period immediately preceding the taxable year (or througho…

  • United States Shareholder

    Within the meaning of the Internal Revenue Code, a U.S. person owning 10 percent or more of the voting stock of a controlled foreign corporation (i.e., one in which U.S. shareholders own 50 percent or more of the voting stock). See SUBPART F….

  • Subpart F

    A provision of the Internal Revenue Code (Sections 951-64) that imposes U.S. income taxes on the undistributed earnings of "controlled foreign corporations." Subpart F was incorporated into the Code by the Revenue Act of 1962; prior to that time, earnings by foreign subsidiaries of U.S. fi…

  • Subpart F

    A provision of the Internal Revenue Code (Sections 951-64) that imposes U.S. income taxes on the undistributed earnings of "controlled foreign corporations." Subpart F was incorporated into the Code by the Revenue Act of 1962; prior to that time, earnings by foreign subsidiaries of U.S. fi…

  • Section 931 Corporation

    It was a corporation operating in various U.S. possessions that, under certain circumstances, might accrue significant tax benefits. So named for Section 931 of the Internal Revenue Code, a firm might be exempt from Federal income tax on U.S. possessions income (so long as the dividends were not dis…

  • Related Foreign Export Corporation

    According to Section 933 of the Internal Revenue Code, any foreign corporation that satisfies the definition of a foreign international sales Corporation, A Real Property Holding Company, or an Associated Foreign Corporation (qq.V.). See Domestic International Sales Corporation….

  • Related Foreign Export Corporation

    According to Section 933 of the Internal Revenue Code, any foreign corporation that satisfies the definition of a foreign international sales Corporation, A Real Property Holding Company, or an Associated Foreign Corporation (qq.V.). See Domestic International Sales Corporation….

  • Doomsday Tax

    The tax obligation incurred by a U.S. firm upon the liquidation of a tax-haven subsidiary. Under Subpart F (read this and related legal terms for further details) of the Internal Revenue Code, the proceeds of such liquid…

  • Branch Rule

    A provision of the Internal Revenue Code that holds that where a controlled foreign corporation operates outside its country of incorporation through a branch, the branch will be treated as a separate corporation in determining foreign base company income, when the branch's activities have &quot…

  • Banking And Financing Controlled Foreign Corporation

    A controlled foreign corporation within the meaning of the Internal Revenue Code, that derives more than 50 percent of its gross income from retail or commercial banking, negotiable paper transactions, or investment banking….

  • Arm's Length Transaction

    An economic transaction between unaffiliated parties undertaken as a product of commercial negotiation or market forces. Section 482 of the Internal Revenue Code authorizes the Internal Revenue Service to reallocate income to a domestic corporation when transactions with a controlled affiliate are u…

  • International Boycott Factor

    An element of Section 999 of the Internal Revenue Code dealing with income derived in support of an international boycott. U.S. policy generally opposes international economic boycotts against friendly nations, and income derived by U.S. firms in furtherance of such boycotts receives adverse tax tre…

  • Philippines

    Legal Materials The Supreme Court of the Philippines posts recent Opinions (2005 to present),Resolutions (1999 to 2008), Court Rules and Circulars & Orders (1994 to 2008). Supreme Court opinions back to 1901 are available free on the Chan Robles Virtual […]

  • Tax Evasion

    Tax evasion is when someone has deliberately misled us about their activities to reduce their tax liability, or have not paid tax that is due. tax evasion is escaping payment by illegal means. This is obviously unlawful and is usually a criminal offence Tax evasion is when a person or a […]