Reports of the United States Tax Court, Volume 106The Court, 1996 |
From inside the book
Results 1-5 of 65
Page 6
... method which is elected . * ( ii ) Profit split.— ( I ) GENERAL RULE . - If an election of this method is in effect , the electing corporation's taxable income derived from the active conduct of a trade or business in a possession with ...
... method which is elected . * ( ii ) Profit split.— ( I ) GENERAL RULE . - If an election of this method is in effect , the electing corporation's taxable income derived from the active conduct of a trade or business in a possession with ...
Page 7
... method elected . CRI elected the " profit - split " method under section 936 ( h ) ( 5 ) ( C ) ( ii ) . Under the profit - split method , the taxable income of the " electing corporation " , with respect to a product produced in a ...
... method elected . CRI elected the " profit - split " method under section 936 ( h ) ( 5 ) ( C ) ( ii ) . Under the profit - split method , the taxable income of the " electing corporation " , with respect to a product produced in a ...
Page 8
... method , as described in § 1.861-8 ( b ) ( 3 ) and ( c ) ( 1 ) . Examples of such meth- ods may include , but are not limited to , those specified in § 1.861-8 ( c ) ( 1 ) ( i ) through ( vi ) . * * * * Question 12 : If the possession ...
... method , as described in § 1.861-8 ( b ) ( 3 ) and ( c ) ( 1 ) . Examples of such meth- ods may include , but are not limited to , those specified in § 1.861-8 ( c ) ( 1 ) ( i ) through ( vi ) . * * * * Question 12 : If the possession ...
Page 12
... method provided therein . The five factors to be determined under Q & A - 12 are as follows : ( 1 ) The electing corporation must determine the sale price of the component product . The sale price is derived from either an independent ...
... method provided therein . The five factors to be determined under Q & A - 12 are as follows : ( 1 ) The electing corporation must determine the sale price of the component product . The sale price is derived from either an independent ...
Page 15
... method that reasonably reflects the factual relationship between the deductions and the income assigned to the grouping . Respondent contends that section 936 ( h ) ( 5 ) ( C ) ( ii ) ( II ) adopts a method of apportioning expenses to ...
... method that reasonably reflects the factual relationship between the deductions and the income assigned to the grouping . Respondent contends that section 936 ( h ) ( 5 ) ( C ) ( ii ) ( II ) adopts a method of apportioning expenses to ...
Contents
268 | |
274 | |
312 | |
319 | |
325 | |
340 | |
355 | |
361 | |
103 | |
110 | |
114 | |
117 | |
137 | |
142 | |
144 | |
155 | |
160 | |
185 | |
207 | |
216 | |
237 | |
245 | |
251 | |
257 | |
386 | |
392 | |
393 | |
394 | |
401 | |
405 | |
418 | |
419 | |
420 | |
430 | |
431 | |
432 | |
436 | |
450 | |
451 | |
461 | |
Other editions - View all
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