Replacement of domestic international sales corporations (DISCs): description of S. 1804 (Foreign Sales Corporation Act) scheduled for a hearing before the Committee on Finance, on November 18, 1983U.S. Government Printing Office, 1983 - 58 pages |
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Common terms and phrases
1st Sess 50 percent 92d Cong administrative pricing rules Agreement allocated arm's-length pricing Article XVI:4 asset test base period cluded combined taxable income Committee contracting parties controlled foreign corporations corporate shareholder countries deemed distributions deferral of tax deferral rate deferred income direct taxes DISC benefits DISC income DISC legislation DISC provisions DISC's dividends earnings and profits economic process effect excess foreign tax exempt foreign trade export activities export income export property export sales export subsidy foreign direct costs foreign sales corporation foreign source income foreign tax credits foreign trade income foreign trading gross FSC proposal income attributable income tax incremental rule International Sales Corporation investment income manufacturing ment private letter ruling related parties requirements signatories small FSC special rule subject to U.S. subpart F tax deferral tax practices taxation taxpayer tion trading gross receipts transaction transfer price Treasury Department U.S. exports U.S. shareholders U.S. tax United Value Added Taxes
Popular passages
Page 11 - Extensive hearings followed before the House Committee on Ways and Means, and the Senate Committee on Finance.
Page 51 - PARTIES in writing of the extent and nature of the subsidization, of the estimated effect of the subsidization on the quantity of the affected product or products imported into or exported from its territory and of the circumstances making the subsidization necessary.
Page 52 - ... in the sale of the product for export at a price lower than the comparable price charged for the like product to buyers in the domestic market...
Page 15 - States persons or ships documented under the laws of the United States in those cases where law or regulations does not require that such property be shipped aboard such airplanes or ships.
Page 52 - If any contracting party should consider that any benefit accruing to it directly or indirectly under this Agreement is being nullified or impaired or that the attainment of any objective of the Agreement is being impeded as the result of (a) the failure of another contracting party to carry out its obligations under this Agreement, or (b) the application by another contracting party of any measure, whether or not it conflicts with the provisions of this Agreement, or (c) the existence of any other...
Page 52 - Members shall: (a) not make a determination to the effect that a violation has occurred, that benefits have been nullified or impaired or that the attainment of any objective of the covered agreements has been impeded, except through recourse to dispute settlement in accordance with the rules and procedures of this Understanding...
Page 32 - For purposes of this part, the term "export property" means property — (A) manufactured, produced, grown, or extracted in the United States by a person other than a DISC, (B) held primarily for sale, lease, or rental, in the ordinary course of trade or business, by...
Page 51 - In any case in which it is determined that serious prejudice to the interests of any other contracting party is caused or threatened by any such subsidization, the contracting party granting the subsidy shall, upon request, discuss with the other contracting party or parties concerned, or with the contracting parties, the possibility of limiting the subsidization.
Page 52 - Agreement as they determine to be appropriate in the circumstances. If the application to any contracting party of any concession or other obligation is in fact suspended, that contracting party shall then be free, not later than sixty days after such action is taken to give written notice to the Executive Secretary...
Page 55 - The Panel was of the view that, given the size and breadth of the export subsidy, it was likely that it had led to an increase in French exports in some sectors and, although the possibility could not be ruled out that the tax arrangements would encourage production abroad and a decrease in exports in other sectors, nonetheless concluded that it was also covered by the notification obligation of Article XVL1.