LAWIN

Search results for: “taxable income”

  • Transfer Pricing Adjustment

    Transfer Pricing Adjustment Additional Adjustments to Be Made in the Wake of a Transfer Pricing Adjustment By Nicholas Webb, BNA Tax Management, for the Tax Management International Forum (2008) In the fact pattern established for the discussion of the first topic, it was assumed that H was a business entity formed under the laws of…

  • Supplemental Retirement Plans

    Supplemental Retirement Plans Tax Treatment of Supplemental Retirement Plans By Nicholas Webb, BNA Tax Management, for the Tax Management International Forum (2008) The following fact pattern formed the background to the discussion of the second topic. H Co. is a large, publicly traded (in Host Country) corporation that operates through subsidiaries in over 100 countries…

  • Partnership

    Introduction to PartnershipPartnership, in law, term applied to an association of two or more persons who have agreed to combine their labor, property, and skill, or some or all of them, for the purpose of engaging in lawful business and sharing profits and losses between them; in this defi…

  • Partnership

    Introduction to PartnershipPartnership, in law, term applied to an association of two or more persons who have agreed to combine their labor, property, and skill, or some or all of them, for the purpose of engaging in lawful business and sharing profits and losses between them; in this defi…

  • Representative Office

    Introduction A representative office is an alternative form to the legal entity, designed for representation of foreign companies. It is often used in the initial stages of an overseas company’s establishment in the targeted market providing the foreign company with a physical presence in […]

  • A Dictionary of Law Enforcement

    A Dictionary of Law Enforcement A Dictionary of Law Enforcement is “the only dictionary available -according to Oxford University Press, its publisher- that focuses on United Kingdom (British) law enforcement terms. This legal resource contains over 3,400 legal terms, covering many United Kingdom and European Union institutions.” Most of the entries in “A Dictionary of…

  • A Dictionary of Law Enforcement

    A Dictionary of Law Enforcement A Dictionary of Law Enforcement is “the only dictionary available -according to Oxford University Press, its publisher- that focuses on United Kingdom (British) law enforcement terms. This legal resource contains over 3,400 legal terms, covering many United Kingdom and European Union institutions.” Most of the entries in “A Dictionary of…

  • 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…

  • Unitary Taxation

    A form of corporate taxation adopted by some U.S. states whereby state income tax is assessed on a pro rata portion of the company's worldwide profits, rather than on locally earned profits only. Unitary taxation emerged in the United States in 1926; at that time it was applied to interstate rai…

  • 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…

  • Foreign Sales Corporation Act

    A component of the Tax Reform Act of 1984, which permits formation of Foreign Sales Corporations (FSC, pronounced "fisk") as a tax incentive to American exporters, and revises tax treatment of income earned by Domestic International Sales Corporations (<a href="http://lawin.org/list-o…

  • Domestic International Sales Corporation

    Commonly known by the acronym DISC, a U.S.-chartered corporation, qualified with the Internal Revenue Service, that derives virtually all of its income from export sales and export-related activities. A properly qualified DISC was permitted to defer indefinitely tax on a portion of its income. The D…

  • China Trade Act Corporation

    A corporation formed under the China Trade Act of 1922, which provided special tax incentives to firms engaged in trade with China. Following the collapse of the Nationalist government on mainland China in 1949, the act was amended to cover only Taiwan and Hong Kong. In its final form, the act provi…