Download or read book Dual Consolidated Loss Regulations Us Internal Revenue Service Regulation Irs 2018 Edition written by The Law The Law Library and published by Createspace Independent Publishing Platform. This book was released on 2018-11-07 with total page 102 pages. Available in PDF, EPUB and Kindle. Book excerpt: Dual Consolidated Loss Regulations (US Internal Revenue Service Regulation) (IRS) (2018 Edition) The Law Library presents the complete text of the Dual Consolidated Loss Regulations (US Internal Revenue Service Regulation) (IRS) (2018 Edition). Updated as of May 29, 2018 This document contains final regulations under section 1503(d) of the Internal Revenue Code (Code) regarding dual consolidated losses. Section 1503(d) generally provides that a dual consolidated loss of a dual resident corporation cannot reduce the taxable income of any other member of the affiliated group unless, to the extent provided in regulations, the loss does not offset the income of any foreign corporation. Similar rules apply to losses of separate units of domestic corporations. These final regulations address various dual consolidated loss issues, including exceptions to the general prohibition against using a dual consolidated loss to reduce the taxable income of any other member of the affiliated group. This book contains: - The complete text of the Dual Consolidated Loss Regulations (US Internal Revenue Service Regulation) (IRS) (2018 Edition) - A table of contents with the page number of each section

Download or read book Unified Rule for Loss on Subsidiary Stock Us Internal Revenue Service Regulation Irs 2018 Edition written by The Law The Law Library and published by Createspace Independent Publishing Platform. This book was released on 2018-11-12 with total page 124 pages. Available in PDF, EPUB and Kindle. Book excerpt: Unified Rule for Loss on Subsidiary Stock (US Internal Revenue Service Regulation) (IRS) (2018 Edition) The Law Library presents the complete text of the Unified Rule for Loss on Subsidiary Stock (US Internal Revenue Service Regulation) (IRS) (2018 Edition). Updated as of May 29, 2018 This document contains final regulations under sections 358, 362(e)(2), and 1502 of the Internal Revenue Code (Code). The regulations apply to corporations filing consolidated returns, and corporations that enter into certain tax-free reorganizations. The regulations provide rules for determining the tax consequences of a member's transfer (including by deconsolidation and worthlessness) of loss shares of subsidiary stock. In addition, the regulations provide that section 362(e)(2) generally does not apply to transactions between members of a consolidated group. Finally, the regulations conform or clarify various provisions of the consolidated return regulations, including those relating to adjustments to subsidiary stock basis. This book contains: - The complete text of the Unified Rule for Loss on Subsidiary Stock (US Internal Revenue Service Regulation) (IRS) (2018 Edition) - A table of contents with the page number of each section

Download or read book United States Code written by United States and published by . This book was released on 2013 with total page 1506 pages. Available in PDF, EPUB and Kindle. Book excerpt: "The United States Code is the official codification of the general and permanent laws of the United States of America. The Code was first published in 1926, and a new edition of the code has been published every six years since 1934. The 2012 edition of the Code incorporates laws enacted through the One Hundred Twelfth Congress, Second Session, the last of which was signed by the President on January 15, 2013. It does not include laws of the One Hundred Thirteenth Congress, First Session, enacted between January 2, 2013, the date it convened, and January 15, 2013. By statutory authority this edition may be cited "U.S.C. 2012 ed." As adopted in 1926, the Code established prima facie the general and permanent laws of the United States. The underlying statutes reprinted in the Code remained in effect and controlled over the Code in case of any discrepancy. In 1947, Congress began enacting individual titles of the Code into positive law. When a title is enacted into positive law, the underlying statutes are repealed and the title then becomes legal evidence of the law. Currently, 26 of the 51 titles in the Code have been so enacted. These are identified in the table of titles near the beginning of each volume. The Law Revision Counsel of the House of Representatives continues to prepare legislation pursuant to 2 U.S.C. 285b to enact the remainder of the Code, on a title-by-title basis, into positive law. The 2012 edition of the Code was prepared and published under the supervision of Ralph V. Seep, Law Revision Counsel. Grateful acknowledgment is made of the contributions by all who helped in this work, particularly the staffs of the Office of the Law Revision Counsel and the Government Printing Office"--Preface.

Download or read book Taxation of International Transactions written by Charles H. Gustafson and published by West Academic Publishing. This book was released on 2011 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Designed for use in law schools, business schools and schools of management, this casebook outlines the determination and administration of U.S. income tax liabilities resulting from international transactions. Textual discussion, cases, rulings and problems, guides students through the basic tax considerations that confront foreign individuals and entities participating in the U.S. economy, and U.S. individuals and entities seeking to derive income abroad. Covers both the U.S. tax rules applicable to international transactions and the tax policy considerations underlying those rules.

Download or read book Statement of Procedural Rules written by United States. Internal Revenue Service and published by . This book was released on 1980 with total page 12 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Tax on Unrelated Business Income of Exempt Organizations written by United States. Internal Revenue Service and published by . This book was released on 1979 with total page 32 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Neutralising the Effects of Branch Mismatch Arrangements Action 2 written by Organization for Economic Development and Cooperation and published by Organization for Economic Co-Operation & Development. This book was released on 2017 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This 2017 report sets out recommendations for branch mismatch rules that would bring the treatment of these structures into line with the treatment of hybrid mismatch arrangements as set out in the 2015 Report on Neutralising the Effects of Hybrids Mismatch Arrangements (Action 2 Report). Branch mismatches arise where the ordinary rules for allocating income and expenditure between the branch and head office result in a portion of the net income of the taxpayer escaping the charge to taxation in both the branch and residence jurisdiction. Unlike hybrid mismatches, which result from conflicts in the legal treatment of entities or instruments, branch mismatches are the result of differences in the way the branch and head office account for a payment made by or to the branch. The 2017 report identifies five basic types of branch mismatch arrangements that give rise to one of three types of mismatches: deduction / no inclusion (D/NI) outcomes, double deduction (DD) outcomes, and indirect deduction / no inclusion (indirect D/NI) outcomes. This report includes specific recommendations for improvements to domestic law intended to reduce the frequency of branch mismatches as well as targeted branch mismatch rules which adjust the tax consequences in either the residence or branch jurisdiction in order to neutralise the hybrid mismatch without disturbing any of the other tax, commercial or regulatory outcomes. The annexes of the report summarise the recommendations and set out a number of examples illustrating the intended operation of the recommended rules.

Download or read book General Explanation of the Tax Reform Act of 1986 written by and published by . This book was released on 1987 with total page 1412 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book OECD G20 Base Erosion and Profit Shifting Project Neutralising the Effects of Hybrid Mismatch Arrangements Action 2 2015 Final Report written by OECD and published by OECD Publishing. This book was released on 2015-10-05 with total page 458 pages. Available in PDF, EPUB and Kindle. Book excerpt: Addressing base erosion and profit shifting (BEPS) is a key priority of governments. In 2013, OECD and G20 countries, working together on an equal footing, adopted a 15-point Action Plan to address BEPS. This publication is the final report for Action 2.

Download or read book The Federal Reserve System Purposes and Functions written by Board of Governors of the Federal Reserve System and published by . This book was released on 2002 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Provides an in-depth overview of the Federal Reserve System, including information about monetary policy and the economy, the Federal Reserve in the international sphere, supervision and regulation, consumer and community affairs and services offered by Reserve Banks. Contains several appendixes, including a brief explanation of Federal Reserve regulations, a glossary of terms, and a list of additional publications.

Download or read book Pension and Annuity Income written by United States. Internal Revenue Service and published by . This book was released on 1990 with total page 32 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book United States Attorneys Manual written by United States. Department of Justice and published by . This book was released on 1988 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Hazard Mitigation Grant Program Desk Reference FEMA 345 written by Federal Emergency Management Agency and published by Createspace Independent Pub. This book was released on 2013-02-01 with total page 236 pages. Available in PDF, EPUB and Kindle. Book excerpt: FEMA's Hazard Mitigation Grant Program is a powerful resource in the combined effort by Federal, State, and local government, as well as private industry and homeowners, to end the cycle of repetitive disaster damage. The Robert T. Stafford Disaster Relief and Emergency Assistance Act was passed on November 23, 1988, amending Public Law 93-288, the Disaster Relief Act of 1974. The Stafford Act included Section 404, which established the Hazard Mitigation Grant Program. In 1993, the Hazard Mitigation and Relocation Act amended Section 404 to increase the amount of HMGP funds available and the cost-share to 75 percent Federal. This amendment also encouraged the use of property acquisition and other non-structural flood mitigation measures. In an effort to streamline HMGP delivery, FEMA encourages States to develop their mitigation programs before disaster strikes. States are adopting a more active HMGP management role. Increased capabilities may include: Conducting comprehensive all-hazard mitigation planning prior to disaster events; Providing applicants technical assistance on sound mitigation techniques and hazard mitigation policy and procedures; Coordinating mitigation programs through interagency teams or councils. Conducting benefit-cost analyses; and Preparing National Environmental Policy Act reviews for FEMA approval. States that integrate the HMGP with their frequently updated State Administrative and Hazard Mitigation Plans will create cohesive and effective approaches to loss reduction. This type of coordinated approach minimizes the distinction between “predisaster” and “post-disaster” time periods, and instead produces an ongoing mitigation effort. Hazard mitigation is any sustained action taken to reduce or eliminate long-term risk to people and property from natural hazards and their effects. A key purpose of the HMGP is to ensure that the opportunity to take critical mitigation measures to protect life and property from future disasters is not lost during the recovery and reconstruction process following a disaster. Program grant funds available under Section 404 of the Stafford Act provide States with the incentive and capability to implement mitigation measures that previously may have been infeasible. The purpose of this Desk Reference is to: Provide comprehensive information about FEMA's Hazard Mitigation Grant Program (HMGP); Increase awareness of the HMGP as an integral part of statewide hazard mitigation efforts; and Encourage deeper commitments and increased responsibilities on the part of all States and communities to reduce damage and losses from natural disasters. This Desk Reference is organized to simplify program information and assist the reader with practical guidance for successful participation in the program. Lists of program-related acronyms and definitions are included, along with appendices that amplify selected aspects of the HMGP. This Desk Reference is organized into 14 sections, each of which presents a major HMGP subject area. In each section, information is presented on the right side of the page. In several sections, job aids containing supplemental material are provided. The job aids for each section can be found at the end of the section. At the front of each section, there is a detailed table of contents to help you locate specific information.

Download or read book U S Tax Guide for Aliens written by United States. Internal Revenue Service and published by . This book was released on 1985 with total page 32 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Technical and Miscellaneous Revenue Act of 1988 written by United States. Congress and published by . This book was released on 1988 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Publicly Traded Partnerships written by Matthew W. Lay and published by . This book was released on with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: " ... analyzes in depth the U.S. federal income taxation of publicly traded partnerships and their partners"--Portfolio description.

Download or read book Credit Method Compatibility and Constraints under EU Law written by Rita Julien and published by Kluwer Law International B.V.. This book was released on 2022-01-13 with total page 520 pages. Available in PDF, EPUB and Kindle. Book excerpt: As European Union (EU) Member States seek to counteract base erosion and profit shifting (BEPS) practices while avoiding new obstacles to the EU’s internal market such as double taxation, the credit method, also known as the foreign tax credit, is one of the essential tools in this balancing act, yet it is one that has given rise to various EU law challenges and questions. This invaluable book – the first in-depth study of the EU law constraints on designing the credit method – delineates the EU law boundaries within which the Member States must operate when they implement this method of tax relief. For the first time, the Court of Justice of the European Union (CJEU) cases that may affect, directly or indirectly, the credit method and its main components are systematically identified and analysed in order to extract the legal findings and principles that define the contours within which the Member States can manoeuvre when considering EU-compatible approaches to the credit method. To this end, among others, this book offers: an extensive study of the historical legal developments of the credit method; an overview of the key design features of the credit method, considering the optional, variable components, such as the credit limitation (maximum creditable amount), that tailor it to different legal and policy considerations; an analysis of the legal constraints on the key features of the credit method flowing from CJEU case law on the fundamental freedoms, considering the impact of landmark cases and concepts (e.g., Schumacker, neutralization); the EU law implications based on the type of credit method (direct, indirect, imputation) and the feature of the credit method (e.g., credit limitation, credit carryforward); and examples to clearly and concisely illustrate the basic operation of the credit method and some of the main calculation and EU law issues. The author’s doctoral dissertation, on which the book is based, was awarded the Wolfgang Gassner Science Prize 2020 and the European Doctoral Tax Thesis Award 2020. As a timely, comprehensive and practical study of the relationship between the credit method and EU law, this book will be welcomed by lawyers and other professionals working with taxation matters, as well as by tax policymakers and academics in the fields of international and European tax law.