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activities addition adjusted allowed alternative amendment amount apply assets attributable base basis beginning benefits bill budget capital claim Code Committee compensation computing considered contributions corporation cost December 31 deduction determined distribution earned effect Effective date election eligible employer ending energy ERISA example excess exclusion exemption expenditures expenses extent facilities Federal filing fiscal foreign tax credit funding gain gift imposed income tax increase individual interest investment issued less liability limitation loss ment method million multiemployer plan obligations operating paid participants partnership payments PBGC percent period permitted present law Prior law production profit proposed provision qualified receipts received reduced regulations resident respect result Revenue effect rules separate spouse taxable taxpayer termination tion transfer treatment treaty trust U.S. tax United withdrawal
Page 7 - royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including...
Page 39 - Generally such relationship exists when the person for whom services are performed has the right to control and direct the individual who performs the services, not only as to the result to be accomplished by the work but also as to the details and means by which that result is accomplished.
Page 106 - ... personal holding company income as defined in section 543, and if at any time during the last half of the taxable year more than 50 percent in value of its outstanding stock is owned, directly or indirectly, by or for not more than five individuals. (Sections 541-547.) Foreign personal holding companies. — Section 551 (a) requires that the undistributed foreign personal holding company income...
Page 1 - Extensive hearings followed before the House Committee on Ways and Means, and the Senate Committee on Finance.
Page 7 - A resolution shall be referred to the Committee on Ways and Means and the Committee on Education and Labor of the House of Representatives and to the Committee on Finance and the Committee on Labor and Human Resources of the Senate.
Page 140 - ... persons who have completed or left high school and who are available for full-time study in preparation for entering the labor market...
Page 171 - At any time during the tax year, did one foreign person own, directly or Indirectly, at least 25% of (a) the total voting power of all classes of stock of the corporation entitled to vote or (b) the total value of all classes of stock of the corporation? If "Yes.
Page 5 - For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishment shall be determined by the same method year by year unless there is good and sufficient reason to the contrary.
Page 177 - December 31, 1978, this section also applies to each activity — (i) engaged in by the taxpayer in carrying on a trade or business or for the production of income, and (ii) which is not described in paragraph (1).
Page 145 - All employees of all corporations that are members of a controlled group of corporations are to be treated as if they were employees of the same corporation for purposes of determining the years of employment of any employee and wages for any employee up to $6,000.