Search results for: “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…
-
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….
-
Offshore Holding Company
Synonymous with foreign base holding company. See SUBPART F….
-
Offshore Trading Company
Synonymous with foreign base trading company. See subpart f….
-
Offshore Holding Company
Synonymous with foreign base holding company. See SUBPART F….
-
Offshore Trading Company
Synonymous with foreign base trading company. See subpart f….
-
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…
-
Carnation Case
A suit in which the U.S. Tax Court denied, for income tax purposes, the deduction of sums paid by the Carnation Company to its wholly owned Captive insurance company (read this and related legal terms for further details…
-
Captive Insurance Company
A subsidiary formed to insure the risks of its noninsurance parent or affiliated companies. The captive may also reinsure risks that have been placed with third- party insurers, all or a portion of which have been transferred subsequently to the captive; in this arrangement, the unrelated insurer is…
-
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 "…
-
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…
-
International trade law Part 20
International Trade law Part 20 221 TRADE TREATY THREATS AND SUB-NATIONAL SOVEREIGNTY: MULTILATERAL TRADE Treaties AND THEIR NEGLIGIBLE IMPACT ON STATE LAWS David I. Spector Hastings International and Comparative Law Review Volume 27, Number 2, Winter 2004 p.367 LAW JOURNAL / LAW REVIEW Advocates of free trade extol the virtues of trade without borders,…
-
International trade law Part 20
International Trade law Part 20 221 TRADE TREATY THREATS AND SUB-NATIONAL SOVEREIGNTY: MULTILATERAL TRADE Treaties AND THEIR NEGLIGIBLE IMPACT ON STATE LAWS David I. Spector Hastings International and Comparative Law Review Volume 27, Number 2, Winter 2004 p.367 LAW JOURNAL / LAW REVIEW Advocates of free trade extol the virtues of trade without borders,…
-
Trade law Part 60
Trade law Part 60 634 CADENCE v. AVANT!: THE UTSA AND CALIFORNIA TRADE SECRET LAW Jeff Danley Berkeley Technology Law Journal Volume 19, Number 1, Annual Review 2004 p.289 LAW JOURNAL / LAW REVIEW 635 TRADE TREATY THREATS AND SUB-NATIONAL SOVEREIGNTY: MULTILATERAL TRADE Treaties AND THEIR NEGLIGIBLE IMPACT ON STATE LAWS David I. Spector…