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additional adjusted Administration ALvoRD American amount answer appear apply banks believe BELL bill capital CHAIRMAN committee concerned consideration CoopFR corporation course Court debt deduction determine difference distributed dividends dollars earnings effect estimated exempt existing fact Federal figures finance foreign funds give going Government HILL included income tax increase individual industry interest investment less loans loss March matter McCoRMACK mean net income OLIPHANT operating paid passed payment percent period position practically present processing tax production profits proposed provision question raise reason received recommendation record reference refund represent reserves result retained returns revenue SARGENT securities situation statement stockholders suggestion surplus taxable taxation thing tion TREADWAY Treasury true understand United WINson
Page 421 - International law is part of our law, and must be ascertained and administered by the courts of justice of appropriate jurisdiction, as often as questions of right depending upon it are duly presented for their determination.
Page 421 - For this purpose, where there is no treaty, and no controlling executive or legislative act or judicial decision, resort must be had to the customs and usages of civilized nations; and, as evidence of these, to the works of jurists and commentators, who by years of labor, research, and experience, have made themselves peculiarly well acquainted with the subjects of which they treat.
Page 729 - The Department of State cannot, of course, require American bankers to consult it. It will not pass upon the merits of foreign loans as business propositions, nor assume any responsibility whatever in connection with loan transactions.
Page 412 - Every such person is hereby made liable for such tax and Is hereby Indemnified against the claims and demands of any person for the amount of any payments made In accordance with the provisions of this section.
Page 729 - The flotation of foreign bond issues in the American market is assuming an increasing importance and on account of the bearing of such operations upon the proper conduct of affairs it is hoped that American concerns that contemplate making foreign loans will inform the Department of State in due time of the essential facts and of subsequent developments of importance.
Page 859 - It is true that Congress cannot convert into a corporation an organization which by the law of its State is deemed to be a partnership. But nothing in the Constitution precludes Congress from taxing as a corporation an association which, although unincorporated, transacts its business as if it were incorporated.
Page 285 - undistributed adjusted net income " means the adjusted net income minus the sum of: (A) 20 per centum of the excess of the adjusted net income over the amount of dividends received from personal holding companies which are allowable as a...
Page 374 - permanent establishment" Includes branches, mines and oil wells, plantations, factories, workshops, warehouses, offices, agencies, installations, and other fixed places of business of an enterprise but does not include the casual or temporary use of merely storage facilities. A permanent establishment of a subsidiary corporation shall not be deemed to be a permanent establishment of the parent corporation.
Page 300 - Stock in trade of the taxpayer or other property of a kind which would properly be included in the inventory of the taxpayer if on hand at the close of the taxable year, or property held by the taxpayer primarily for sale to customers in the ordinary course of his trade or business...