Hearings, Reports and Prints of the Joint Committee on TaxationU.S. Government Printing Office, 1979 - Income tax |
From inside the book
Results 1-5 of 89
Page 10
... election was intended to accommodate differ- ing types of foreign ventures . It was felt that a multinational com- pany functioning as a single integrated business enterprise in a num- ber of countries should be allowed to credit taxes ...
... election was intended to accommodate differ- ing types of foreign ventures . It was felt that a multinational com- pany functioning as a single integrated business enterprise in a num- ber of countries should be allowed to credit taxes ...
Page 16
... election to use the per - country limitation , requiring use of the overall limitation , and required recapture of overall foreign loses for all taxpayers . ( As ex- plained in the following sections , essentially these same rules were ...
... election to use the per - country limitation , requiring use of the overall limitation , and required recapture of overall foreign loses for all taxpayers . ( As ex- plained in the following sections , essentially these same rules were ...
Page 20
... election to deduct intangible drilling costs ) . Most oil com- panies pay foreign oil taxes at an overall rate substantially higher than their aggregate U.S. tax on their net income from foreign extraction activities . Without this ...
... election to deduct intangible drilling costs ) . Most oil com- panies pay foreign oil taxes at an overall rate substantially higher than their aggregate U.S. tax on their net income from foreign extraction activities . Without this ...
Page 6
... election of a plan . 6. Multiemployer guarantees Since ERISA was enacted in 1974 , the guarantee of employee bene- fits under terminated multiemployer plans has been within the discre- tion of the PBGC , subject to statutory standards ...
... election of a plan . 6. Multiemployer guarantees Since ERISA was enacted in 1974 , the guarantee of employee bene- fits under terminated multiemployer plans has been within the discre- tion of the PBGC , subject to statutory standards ...
Page 40
... election of a plan . Such guaran- tees must be financed only from premiums collected for this program . Effective date These provisions of the bill would apply on the date of enactment . F. Multiemployer Guarantees ; Aggregate Limit on ...
... election of a plan . Such guaran- tees must be financed only from premiums collected for this program . Effective date These provisions of the bill would apply on the date of enactment . F. Multiemployer Guarantees ; Aggregate Limit on ...
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Common terms and phrases
Act and sec Act provides adjusted allowed alternative minimum tax amendment amount basis benefits bill capital gains carryover Code compensation Congress believes contributions corporation date The provision decedent December 31 deduction deferred determined earned income effect This provision Effective date election eligible employer ERISA estate tax excess excise tax exemption Explanation of provision facilities Federal filing foreign tax credit gift tax gross income income tax increase individual interest Internal Revenue Service investment credit itemized deductions joint return limitation loss married couples ment minimum tax multiemployer plan partnership payments PBGC percent period present law Prior law production proposed treaty provision The Act qualified Reasons for change refund regulations resident respect Revenue effect rules spouse tax expenditures tax liability tax rate tax treaty taxable income taxable years beginning taxation taxpayer tion trade or business trust U.S. tax United windfall profit tax
Popular passages
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 45 - 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.