 State, and in either case conditions are made or imposed between the two enterprises in their commercial or financial relations which differ from those which would be made between independent enterprises, then any profits which would, but for those conditions,...  Internal Revenue Cumulative Bulletin - Page 402by United States. Internal Revenue Service - 1977Full view - About this book
 | United States. Congress. Senate. Committee on Finance - 1946 - 910 pages
...financial relations, conditions different from those which would be made with an independent enterprise, any profits which would but for those conditions have...profits of that enterprise and taxed accordingly. ARTICLE V 1380 00 STAT.] UNITED KINGDOM— DOUBLE TAXATION1381 aircraft registered under the laws of... | |
 | United States. Congress. Senate. Foreign Relations - 1945 - 94 pages
...financial relations, conditions different from those which would be made with an independent enterprise, any profits which would but for those conditions have...profits of that enterprise and taxed accordingly. Hence, the Treasury now has recognition of its powers under section 45 to assure the proper allocation... | |
 | United States. Congress. Senate. Committee on Foreign Relations - 1945 - 138 pages
...financial relations, conditions different from those which would be made with an independent enterprise, any profits which would but for those conditions have...profits of that enterprise and taxed accordingly. ARTICLE v (1) Notwithstanding the provisions of Articles III and IV of the present Convention, profits... | |
 | United States. Congress. Joint Committee on Internal Revenue Taxation - 1946 - 428 pages
...financial relations, conditions different from those which would be made with an independent enterprise, any profits which would but for those conditions have...profits of that enterprise and taxed accordingly. Article V (1) Notwithstanding the provisions of Articles III and IV of the present Convention, profits... | |
 | 1968 - 416 pages
...financial relations, conditions different from those which would be made with an Independent enterprise, any profits which would but for those conditions have...profits of that enterprise and taxed accordingly. ARTICLE v (1) Notwithstanding the provisions of Articles Ш of IV of the present Convention, profits... | |
 | 1992 - 858 pages
...other Contracting State, and in either case conditions are made or imposed between the two enterprises in their commercial or financial relations which differ...between independent enterprises, then any profits which, but for those conditions, would have accrued to one of the enterprises, but by reason of those conditions... | |
 | United States. Congress. Senate. Committee on Finance - 1993 - 484 pages
...would be made between independent enterprises, then any profits which, but for those conditions would have accrued to one of the enterprises, but by reason...profits of that enterprise and taxed accordingly. [Emphasis added] Administrative Stafljng Requirements: Federal §482 vs. Global Formula Apportionment... | |
 | United States. Congress. Senate. Committee on Governmental Affairs - 1993 - 360 pages
...be made between independent enterprises, then any profits which, but for those fir?)ditioiin would have accrued to one of the enterprises, but by reason...profits of that enterprise and taxed accordingly. [Emphasis added] 14. That Treasury itself believes that some form* of formula apportionment are consistent... | |
 | 1993 - 116 pages
...transactions between related enterprises, if conditions are made or imposed between the two enterprises in their commercial or financial relations which differ...which would be made between independent enterprises. In such a case, a country could allocate to such an enterprise the profits which it would have accrued,... | |
 | 1997 - 68 pages
...transactions between related enterprises, if conditions are made or imposed between the two enterprises in their commercial or financial relations which differ...which would be made between independent enterprises. In such a case, a country may allocate to such an enterprise the profits which it would have accrued... | |
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