Documents

Corporate Taxation: Profit Shifting, Transfer Pricing, and Cost Sharing

Congressional research report · CRS In Focus · Nov 1, 2023

The Internal Revenue Code (IRC) section that governs transfer pricing, Section 482, is a brief section, general in nature, which consists of three sentences. … Under current law, a U.S. tax is imposed on foreign source income from intangibles (the tax on Global Intangible Low Taxed Income, or GILTI), but the tax rate is lower than the U.S. rate and can be reduced

Military Readiness: DOD Assessment and Reporting Requirements

Congressional research report · CRS In Focus · Oct 26, 2022

Secretary of Defense Responsibilities Title 10, Section 117 of the U.S. … Nicastro, Analyst in U.S.

The Possible Elimination of Chevron Deference: Potential Implications for Tax Revenue and Administration

Congressional research report · CRS In Focus · Apr 8, 2024

The statute governing the allocation of income and deductions, contained in Section 482 of the Internal Revenue Code, is general and brief, so the methods to allocate profits are contained in Treasury … One method of profit shifting is cost sharing, where a U.S. firm’s foreign subsidiary makes a buy-in payment to existing technology, then shares in the costs of further development for the right to a share

Currency Exchange Rate Policies and the World Trade Organization Subsidies Agreement

Congressional research report · CRS In Focus · May 16, 2016

They argue that although that subsidy may benefit U.S. consumers through lower prices, it may also harm U.S. import-competing firms and their workers. … Int’l L. 423, 449-451 (2011). In addition, the member imposing CVDs might encounter difficulty in calculating the benefit conferred. See ASCM Art. 14.

Social Security Benefits and Unauthorized Alien Workers

Congressional research report · CRS In Focus · Feb 6, 2018

[Social Security Act, §214 and §223; 42 U.S.C. §414 and §423]  If the individual has work authorization at some point, all of his or her Social Security-covered earnings (from authorized and unauthorized … Can Noncitizens in the U.S. Receive Social Security Benefit Payments If They Are Not Lawfully Present? No.

National Park Service: FY2021 Appropriations

Congressional research report · CRS In Focus · Oct 12, 2021

Updated October 12, 2021 National Park Service: FY2021 Appropriations The National Park Service (NPS) administers the National Park System, which includes 423 units valued for their natural, cultural, … colleges and universities, and historic revitalization, as well as the Save America’s Treasures program (which preserves nationally significant sites, structures, and artifacts) and sites related to the U.S

Bank Mergers and Acquisitions

Congressional research report · CRS In Focus · Oct 28, 2021

Recent IDI M&As Among Top 25 BHCs By BHC consolidated assets, as of June 30, 2021 Assets ($billion) M&A Date U.S. … Most of the largest U.S. banks are structured as bank holding companies (BHCs), and their M&As are approved by the Fed.

U.S. Export Controls and China

Congressional research report · CRS In Focus · Mar 24, 2022

U.S. … In 2020, BIS denied three of 482 licenses to release U.S.-controlled technology and knowhow to PRC nationals. https://crsreports.congress.gov U.S.

National Park Service: FY2022 Appropriations

Congressional research report · CRS In Focus · May 19, 2022

Updated May 19, 2022 National Park Service: FY2022 Appropriations The National Park Service (NPS) administers the National Park System, which includes 423 units valued for their natural, cultural, and … colleges and universities, and historic revitalization, as well as the Save America’s Treasures program (which preserves nationally significant sites, structures, and artifacts) and sites related to the U.S

Trends in Commemorative Legislation, 93rd Through 115th Congresses

Congressional research report · CRS In Focus · Aug 31, 2020

Types of Commemorative Legislation Source: U.S. Mint, “Doolittle Tokyo Raiders,” at https://www.usmint.gov/coins/coin-medal-programs/medals/doolittletokyo-raiders; and U.S. … Enacted/Agreed to 93 633 44 94 759 49 95 852 57 96 540 97 97 650 148 98 808 224 99 938 296 100 928 281 101 799 243 102 711 203 103 616 154 104 232 86 105 335 95 106 482

TPP: U.S.-Japan Issues

Congressional research report · CRS In Focus · Aug 23, 2016

 Pork: Minimum import price lowered from ¥482/Kg to ¥50/Kg, and a 4.3% tariff eliminated, both by year 10. … for U.S.

Legislation to Repeal Mandatory Securities Arbitration

Congressional research report · CRS In Focus · Apr 5, 2022

Since then, two U.S. Supreme Court rulings, Shearson/American Express v. McMahon, 482 U.S. 220 (1987) and R. de Quijas v. Shearson/Am. … (PIABA) Arguments Critical of the Legislations’ Intent Among critics of the bills are the U.S.

A U.S.-China Bilateral Investment Treaty (BIT): Issues and Implications

Congressional research report · CRS In Focus · Jan 12, 2018

U.S. … BEA estimates sales of foreign affiliates of U.S. firms in China totaled $482 billion in 2015.

TPP: Selected Commodity Impacts for U.S. Agriculture

Congressional research report · CRS In Focus · Nov 19, 2015

A separate duty on pork cuts under Japan’s “gate price system,” which acts as a minimum import price, would be lowered immediately to 125 yen per kilogram, from 482 yen now. … 2.4% of U.S. sugar imports in 2014/2015.

Freshwater Harmful Algal Blooms: An Overview

Congressional research report · CRS In Focus · Jul 8, 2020

Congress most recently reauthorized HABHRCA in January 2019 (P.L. 115-423), requiring the task force to submit a scientific assessment of HABs once every five years, requiring the National Oceanic and … (For information on financial assistance for agricultural nutrient management from the U.S.

Key Issues in Tax Reform: International Tax Issues

Congressional research report · CRS In Focus · Dec 12, 2017

The U.S. system has elements of both. … The payments exclude interest, certain other financial payments, and the cost of services with no markup if the payor uses a services cost method under Section 482 (transfer pricing rules).

U.S. Relations with Burma: Key Issues in 2020

Congressional research report · CRS In Focus · Jan 24, 2020

Updated January 24, 2020 U.S. … Status of U.S.

EU-Japan FTA: Implications for U.S. Trade Policy

Congressional research report · CRS In Focus · Jun 26, 2020

In contrast to U.S. FTAs, however, EU-Japan commitments do not cover some U.S. priorities, while others are sensitive issues for the U.S. bilaterally with the EU and Japan. … reduced to 9% over 15 years; Dairy (e.g., cheese): Hard cheeses tariffs up to 29.8% eliminated over15 years; soft, fresh cheeses given dutyfree TRQs that expand over time; Pork: 4.3% tariff eliminated and 482