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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 ...
Section 482 of the Internal Revenue Code allows for a reallocation of income from the Loan-Out corporation to the individual, if necessary to avoid unintended tax evasion, or to more reasonably reflect the genuine revenues generated by the corporation.
John Clark. Section 482 of the Income and Corporation Taxes Act 1970. Institute of Taxation. 1980. Google; Halsbury's Laws of England. Fourth Edition. Butterworths. London. 1978. Volume 23. Title "Income Taxation". Passim. Reviewed at "Reviews" (1979) 123 The Solicitors' Journal 46 (19 January 1979). 1983-84 British Master Tax Guide. CCH ...
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The majority placed particular reliance on two arguments. The first being the presence of the past participle adjective "formed" which, in their Honours' opinion, restricted the section to companies which had already been formed. The second argument relied on were the speeches and notes of the Constitutional Convention debates.
Section 61 of the Internal Revenue Code (IRC 61, 26 U.S.C. § 61) defines "gross income," the starting point for determining which items of income are taxable for federal income tax purposes in the United States. Section 61 states that "[e]xcept as otherwise provided in this subtitle, gross income means all income from whatever source derived
Yellow Cab Co., the Supreme Court acknowledged the Legislature's original intent in enacting Civil Code section 1714 [14] to codify a contributory negligence scheme subject to the last clear chance doctrine, then held the legislature had not intended to freeze the common law in place and proceeded to judicially adopt comparative negligence. In ...
How To Make My 5-Ingredient Crab Pasta. For 2 servings as an entrée or 4 as part of a larger meal, you’ll need: 1 medium lemon. 1 tablespoon salt, plus more for seasoning