Reports of the United States Tax Court, Volume 106The Court, 1996 |
From inside the book
Results 1-5 of 80
Page 3
... investment and employment in Puerto Rico and other possessions of the United States . The amount of the credit is derived from the amount of the " combined taxable income " ( sometimes referred to as CTI ) derived from the " possession ...
... investment and employment in Puerto Rico and other possessions of the United States . The amount of the credit is derived from the amount of the " combined taxable income " ( sometimes referred to as CTI ) derived from the " possession ...
Page 5
... INVESTMENT INCOME . - The term " qualified possession source investment income " means gross income which- ( A ) is from sources within a possession of the United States in which a trade or business is actively conducted , and ( B ) the ...
... INVESTMENT INCOME . - The term " qualified possession source investment income " means gross income which- ( A ) is from sources within a possession of the United States in which a trade or business is actively conducted , and ( B ) the ...
Page 21
... investments in possessions of the United States . Amer- ican companies operating in the possessions originally were subjected to double taxation by the imposition of both the Federal corporate income tax and the taxes levied by the ...
... investments in possessions of the United States . Amer- ican companies operating in the possessions originally were subjected to double taxation by the imposition of both the Federal corporate income tax and the taxes levied by the ...
Page 22
... investment of possessions - source earnings in the United States , Congress , in 1976 , enacted section 936 . Tax Reform Act of 1976 , Pub . L. 94-455 , sec . 1051 , 90 Stat . 1643. The Tax Reform Act of 1976 revised prior law , provid ...
... investment of possessions - source earnings in the United States , Congress , in 1976 , enacted section 936 . Tax Reform Act of 1976 , Pub . L. 94-455 , sec . 1051 , 90 Stat . 1643. The Tax Reform Act of 1976 revised prior law , provid ...
Page 23
... invest- ment incentives and the U.S. tax laws because of the important role it is believed they play in keeping investment in the possessions competitive with investment in neighboring countries . *** [ S. Rept . 94-938 , at 277-278 ...
... invest- ment incentives and the U.S. tax laws because of the important role it is believed they play in keeping investment in the possessions competitive with investment in neighboring countries . *** [ S. Rept . 94-938 , at 277-278 ...
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Common terms and phrases
1989 agreement 9th Cir affd allocable alternative minimum tax amended apply Arkla assets benefits business expense cardholder CBOT Citibank cluster home Commis Commissioner Congress contract corporation cost Court of Appeals debt decedent decedent's deduction determined election employees estate tax executor Federal income tax filed funds gross income Guardian Income Tax Regs Internal Revenue Code investment Irwindale issue litigation loan Los Angeles Raiders Malibu marital deduction MasterCard meals ment Mexican pesos Nihon Intergraph obligation overdraft amount paid parties payment percent peti petitioner Petitioner argues petitioner's possession product purchase purposes pursuant QTIP Raiders received refund regulations reinsurance reinsurance agreement Rept respondent's rule statute summary judgment supra surviving spouse T.C. Memo tax avoidance Tax Court tax deficiencies tax return taxable income taxpayer Temporary Income Tax terminable interest tion tioner trade or business transaction transfer fees trust United VEBA