Reports of the United States Tax Court, Volume 134United States Tax Court, 2010 Kept up to date by a monthly publication called: United States. Tax Court. Reports. |
From inside the book
Results 1-5 of 40
Page 10
... foreign policy . Sec . 6110 ( c ) ( 1 ) , ( 2 ) , ( 5 ) . III . Confidential Return Information Under Section 6103 Section 6103 protects the privacy of taxpayers and restricts Government officers and employees from disclosing confiden ...
... foreign policy . Sec . 6110 ( c ) ( 1 ) , ( 2 ) , ( 5 ) . III . Confidential Return Information Under Section 6103 Section 6103 protects the privacy of taxpayers and restricts Government officers and employees from disclosing confiden ...
Page 130
... foreign corpora- tion , " but only to the extent the amount so received is not effectively connected with the conduct of a trade or business within the United States . " Taxes owed under section 881 ( a ) 7 Unless otherwise noted all ...
... foreign corpora- tion , " but only to the extent the amount so received is not effectively connected with the conduct of a trade or business within the United States . " Taxes owed under section 881 ( a ) 7 Unless otherwise noted all ...
Page 133
... foreign subsidiary by a third party without receiving compensation from the foreign sub , it could avoid the income it would have incurred had it charged a fee . But the guaranty adds some value , and the section 482 regula- tions tell ...
... foreign subsidiary by a third party without receiving compensation from the foreign sub , it could avoid the income it would have incurred had it charged a fee . But the guaranty adds some value , and the section 482 regula- tions tell ...
Page 137
... foreign buyer , assessing the creditworthiness of the foreign buyer can be a problem . So , instead of having the seller do it , the buyer requests a letter of credit from a foreign bank and the foreign bank does the job . If the buyer ...
... foreign buyer , assessing the creditworthiness of the foreign buyer can be a problem . So , instead of having the seller do it , the buyer requests a letter of credit from a foreign bank and the foreign bank does the job . If the buyer ...
Page 138
... foreign bank could default . The Court of Claims again found that the performance of services was a part of the deal but that its predominant feature was BofA's substituting its credit for the opening bank's . Id . at 691 , 680 F.2d at ...
... foreign bank could default . The Court of Claims again found that the performance of services was a part of the deal but that its predominant feature was BofA's substituting its credit for the opening bank's . Id . at 691 , 680 F.2d at ...
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