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Foreign corporations are subject to tax on such income at regular corporate income tax rates. The branch profits tax under Internal Revenue Code section 884 may apply, subject to the branch termination exception. The alternative minimum tax may also apply.
The tax statutes were re-codified by an Act of Congress on February 10, 1939 as the "Internal Revenue Code" (later known as the "Internal Revenue Code of 1939"). The 1939 Code was published as volume 53, Part I, of the United States Statutes at Large and as title 26 of the United States Code.
Internal Revenue Code section 6109(d) provides: "The social security account number issued to an individual for purposes of section 205(c)(2)(A) of the Social Security Act [codified as 42 U.S.C. § 405(c)(2)(A)] shall, except as shall otherwise be specified under regulations of the Secretary [of the Treasury or his delegate], be used as the ...
Section 482 applies to all transactions between related parties and commonly controlled parties, regardless of taxpayer intent, according to regulatory guidance. To avoid tax evasion or to clearly reflect their income, the IRS may change the income, deductions, credits, or allowances of frequently managed taxpayers under Section 482 of the Code ...
Showdown at Gucci Gulch: Lawmakers, Lobbyists and the Unlikely Triumph of Tax Reform (1987), by Jeffrey Birnbaum and Alan Murray, is a book about the bill's passage. Full text of the Act; Apps, P. F. (2010, June). Why the Henry Review Fails on Family Tax Reform. In Australia’s Future Tax System: A Post-Henry Review'Conference, Sydney
Corporate tax rates generally are the same for differing types of income, yet the US graduated its tax rate system where corporations with lower levels of income pay a lower rate of tax, with rates varying from 15% on the first $50,000 of income to 35% on incomes over $10,000,000, with phase-outs.
Internal Revenue Code 861, 26 U.S.C. § 861, titled "Income from sources within the United States" is a provision of the Internal Revenue Code which lists "The following items of gross income shall be treated as income from sources within the United States", for purposes of various taxes imposed by Subchapter N (sections 861 through 999) of Chapter 1 of Subtitle A of the Code.
The United States Revenue Act of 1978, Pub. L. 95–600, 92 Stat. 2763, enacted November 6, 1978, amended the Internal Revenue Code by reducing individual income taxes (widening tax brackets and reducing the number of tax rates), increasing the personal exemption from $750 to $1,000, reducing corporate tax rates (the top rate falling from 48 percent to 46 percent), increasing the standard ...