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Articles 1 - 6 of 6
Full-Text Articles in Taxation-Transnational
Recapture Of Past Foreign Branch Losses On Transfer Of Branch Assets To A Foreign Corporation, E.C. Jr. Lashbrooke
Recapture Of Past Foreign Branch Losses On Transfer Of Branch Assets To A Foreign Corporation, E.C. Jr. Lashbrooke
Northwestern Journal of International Law & Business
A domestic corporation operating in a foreign country through a branch office includes income from that operation in its worldwide income and deducts losses from its worlwide income. Net losses from foreign branch operations reduce the amount of income subject to the federal income tax. If at a future date the domestic corporation incorporates its foreign branch and transfers the branch assets to the foreign corporation in exchange for its stock or securities, any future unearned income of the foreign corporation is removed from United States tax jurisdiction, provided that the foreign corporation does not engage in the conduct of …
Taxation: Tribal Taxation, Secretarial Approval, And State Taxation--Merrion And Beyond, David B. Wiles
Taxation: Tribal Taxation, Secretarial Approval, And State Taxation--Merrion And Beyond, David B. Wiles
American Indian Law Review
No abstract provided.
United Kingdom: Tax Avoidance And The Courts, Hugh Ault, Philip Kaplan
United Kingdom: Tax Avoidance And The Courts, Hugh Ault, Philip Kaplan
Hugh J. Ault
No abstract provided.
Fremdfinanzierung Von Kapitalgesellschäften Durch Anteilseigner Im Steuerrecht Der Usa, Hugh Ault
Fremdfinanzierung Von Kapitalgesellschäften Durch Anteilseigner Im Steuerrecht Der Usa, Hugh Ault
Hugh J. Ault
No abstract provided.
Germany: Thin Capitalization Revisited, Hugh Ault, Philip Kaplan
Germany: Thin Capitalization Revisited, Hugh Ault, Philip Kaplan
Hugh J. Ault
No abstract provided.
United States: More On Unitary Taxation Of Multinational Groups, Hugh Ault
United States: More On Unitary Taxation Of Multinational Groups, Hugh Ault
Hugh J. Ault
No abstract provided.