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" In the case of a taxpayer engaged in a trade or business in which both personal services and capital are material income-producing factors... "
Internal Revenue Cumulative Bulletin - Page 524
by United States. Internal Revenue Service - 1981
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Code of Federal Regulations: Containing a Codification of Documents of ...

1970 - 940 pages
...United States." Thus, in tin case of a citizen of the United States conducting, in a foreign country, a trade or business in which both personal services and capital are material income-producing factors, a»y part of the income therefrom which is excluded from gross income as earned income under the prov.sions...
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The Code of Federal Regulations of the United States of America

1976 - 412 pages
...case of an Individual who Is an employee within the meaning of paragraph (1) and who le engaged in a trade or business in which both personal services and capital are material Income-producing factor» and with respect to which the Individual actually renders personal services on a full-time,...
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Postponement of Income Tax on Income Set Aside for Retirement: Hearing ...

United States. Congress. House. Committee on Ways and Means - 1952 - 212 pages
...illness or cyclical unemployment.5 However, a In cases wnere the taxpayer is a partner or propietor in a trade or business in which both personal services and capital are material income-producing factors, a determination of the portion of the income attributable to personal services wo'ild be made under...
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Internal Revenue Bulletin: Cumulative bulletin, Part 3

United States. Internal Revenue Service - 1963 - 1402 pages
...profits rather than a reasonable allowance as compensation for tl personal services actually rendered. In the case of a taxpayer engaged in trade or business...which both personal services and capital are material i; corne-producing factors, under regulations prescribed by the Secretary or b delegate, a reasonable...
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General Revenue Revision: Topics 1-19. June 16-18, 23, July 8-9, 14-16, and ...

United States. Congress. House. Committee on Ways and Means - 1953 - 1482 pages
...because of the difficulty of determining earned income in situations where the taxpayer is engaged in a trade or business in which both personal services and capital are material income-producing factors. I may say that the reason we have geared the exclusion to earned income is because that is the basis...
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Internal Revenue Bulletin: Cumulative bulletin

United States. Internal Revenue Service - 1967 - 1510 pages
...Internal Revenue Code of 1954. Another partnership is engaged, in the United States and abroad, in a business in which both personal services and capital are material income-producing factors. The partnership agreement provides that a partner assigned to a foreign branch is to receive his entire...
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The Internal Revenue Code of 1954: Hearings Before the Committee ..., Parts 3-4

United States. Congress. Senate. Committee on Finance - 1954 - 1472 pages
...the bill (sec. 911 d)in the case of individual bona fide nonresidents when a taxpayer is engaged in a trade or business in which both personal services...capital are material income-producing factors, the maximum allowance as compensation for personal services has been increased from 20 percent to 30 percent,...
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The Supplemental Appropriation Bill, 1956, [exclusive of Military ...

United States. Congress. House. Committee on Appropriations - 1955 - 1050 pages
...any payment which represents a distribution of earnings or profits. If the taxpayer is engaged in a trade or business in which both personal services and capital are material income-producing factors, a reasonable allowance, not to exceed 30 percent of his share of the net profits, is considered to...
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The Supplemental Appropriation Bill: 1956, Hearings ... 84th Congress, 1st ...

United States. Congress. House. Appropriations - 1955 - 1092 pages
...any payment which represents a distribution of earnings or profits. If the taxpayer is engaged in a trade or business in which both personal services and capital are material income-producing factors, a reasonable allowance, not to exceed 30 percent of his share of the net profits, is considered to...
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Individual Retirement Act of 1955: Hearings Before the Committee on Ways and ...

United States. Congress. House. Committee on Ways and Means - 1955 - 298 pages
...because of the difficulty of determining earned income in situations where the taxpayer is engaged in a trade or business in which both personal services and capital are material income-producing factors. I may say that the reason we have geared the exclusion to earned income is because that is the basis...
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