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Author: The Law The Law Library Publisher: Createspace Independent Publishing Platform ISBN: 9781729728970 Category : Languages : en Pages : 26
Book Description
Section 1248 Attribution Principles (US Internal Revenue Service Regulation) (IRS) (2018 Edition) The Law Library presents the complete text of the Section 1248 Attribution Principles (US Internal Revenue Service Regulation) (IRS) (2018 Edition). Updated as of May 29, 2018 This document contains final regulations under section 1248 of the Internal Revenue Code (Code) that provide guidance for determining the earnings and profits attributable to stock of controlled foreign corporations (or former controlled foreign corporations) that are (were) involved in certain nonrecognition transactions. The final regulations are necessary in order to supplement and clarify existing guidance in the regulations under section 1248. The final regulations affect persons subject to the regulations under section 1248, as well as persons to which regulations under other Code provisions, such as section 367(b), apply to the extent that those regulations incorporate the principles of the section 1248 regulations. In addition, the final regulations provide that with respect to the sale by a foreign partnership of the stock of a corporation, the partners in such foreign partnership shall be treated as selling or exchanging their proportionate share of the stock of such corporation for purposes of section 1248. This book contains: - The complete text of the Section 1248 Attribution Principles (US Internal Revenue Service Regulation) (IRS) (2018 Edition) - A table of contents with the page number of each section
Author: The Law The Law Library Publisher: Createspace Independent Publishing Platform ISBN: 9781729728970 Category : Languages : en Pages : 26
Book Description
Section 1248 Attribution Principles (US Internal Revenue Service Regulation) (IRS) (2018 Edition) The Law Library presents the complete text of the Section 1248 Attribution Principles (US Internal Revenue Service Regulation) (IRS) (2018 Edition). Updated as of May 29, 2018 This document contains final regulations under section 1248 of the Internal Revenue Code (Code) that provide guidance for determining the earnings and profits attributable to stock of controlled foreign corporations (or former controlled foreign corporations) that are (were) involved in certain nonrecognition transactions. The final regulations are necessary in order to supplement and clarify existing guidance in the regulations under section 1248. The final regulations affect persons subject to the regulations under section 1248, as well as persons to which regulations under other Code provisions, such as section 367(b), apply to the extent that those regulations incorporate the principles of the section 1248 regulations. In addition, the final regulations provide that with respect to the sale by a foreign partnership of the stock of a corporation, the partners in such foreign partnership shall be treated as selling or exchanging their proportionate share of the stock of such corporation for purposes of section 1248. This book contains: - The complete text of the Section 1248 Attribution Principles (US Internal Revenue Service Regulation) (IRS) (2018 Edition) - A table of contents with the page number of each section
Author: The Law The Law Library Publisher: Createspace Independent Publishing Platform ISBN: 9781729734568 Category : Languages : en Pages : 34
Book Description
Surrogate Foreign Corporations (US Internal Revenue Service Regulation) (IRS) (2018 Edition) The Law Library presents the complete text of the Surrogate Foreign Corporations (US Internal Revenue Service Regulation) (IRS) (2018 Edition). Updated as of May 29, 2018 This document contains final regulations regarding whether a foreign corporation is treated as a surrogate foreign corporation. The final regulations affect certain domestic corporations and partnerships (and certain parties related thereto), and foreign corporations that acquire substantially all of the properties of such domestic corporations or partnerships. This book contains: - The complete text of the Surrogate Foreign Corporations (US Internal Revenue Service Regulation) (IRS) (2018 Edition) - A table of contents with the page number of each section
Author: Charles H. Gustafson Publisher: West Academic Publishing ISBN: 9780314911711 Category : Casebooks Languages : en Pages : 0
Book Description
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.
Author: Patrick A. Gaughan Publisher: John Wiley & Sons ISBN: 1119380731 Category : Business & Economics Languages : en Pages : 819
Book Description
The essential M&A primer, updated with the latest research and statistics Mergers, Acquisitions, and Corporate Restructurings provides a comprehensive look at the field's growth and development, and places M&As in realistic context amidst changing trends, legislation, and global perspectives. All-inclusive coverage merges expert discussion with extensive graphs, research, and case studies to show how M&As can be used successfully, how each form works, and how they are governed by the laws of major countries. Strategies and motives are carefully analyzed alongside legalities each step of the way, and specific techniques are dissected to provide deep insight into real-world operations. This new seventh edition has been revised to improve clarity and approachability, and features the latest research and data to provide the most accurate assessment of the current M&A landscape. Ancillary materials include PowerPoint slides, a sample syllabus, and a test bank to facilitate training and streamline comprehension. As the global economy slows, merger and acquisition activity is expected to increase. This book provides an M&A primer for business executives and financial managers seeking a deeper understanding of how corporate restructuring can work for their companies. Understand the many forms of M&As, and the laws that govern them Learn the offensive and defensive techniques used during hostile acquisitions Delve into the strategies and motives that inspire M&As Access the latest data, research, and case studies on private equity, ethics, corporate governance, and more From large megadeals to various forms of downsizing, a full range of restructuring practices are currently being used to revitalize and supercharge companies around the world. Mergers, Acquisitions, and Corporate Restructurings is an essential resource for executives needing to quickly get up to date to plan their own company's next moves.
Author: Organization for Economic Development and Cooperation Publisher: Organization for Economic Co-Operation & Development ISBN: 9789264277953 Category : Corporations Languages : en Pages : 0
Book Description
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.
Author: OECD Publisher: OECD Publishing ISBN: 9264241132 Category : Languages : en Pages : 458
Book Description
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.
Author: United Nations Publisher: UN ISBN: 9789211482720 Category : Political Science Languages : en Pages : 277
Book Description
The Global Study on Homicide 2013 is based on comprehensive data from more than 200 countries/territories, and examines and analyses patterns and trends in homicide at the global, regional, national and sub-national levels. Such analysis is fundamental to understanding the various factors and dynamics that drive homicide, so that measures can be developed to reduce violent crime. The Study provides a typology of homicide, including homicide related to crime, coexistence-related homicide, and socio-political homicide. The nature of crime in several countries emerging from conflict, the role of various mechanisms in killing, and the response of the criminal justice system to homicide are also analyzed. A further chapter examines homicide at the sub-national level, and includes analysis at the city-level for selected global cities.
Author: The Law The Law Library
Author: The Law The Law Library
Author: United States. Congress. Senate. Committee on the Budget
Author: The Law The Law Library
Author: Charles H. Gustafson
Author: 
Author: Stephen M. Byars
Author: Patrick A. Gaughan
Author: Organization for Economic Development and Cooperation
Author: OECD
Author: United Nations