Documents

Compensatory Stock Options Under Section 482

Federal Register · Rule · Aug 26, 2003

No. 99-426, at 423-25 (1985). … . generally accepted accounting principles (U.S.

Compensatory Stock Options Under Section 482

Federal Register · Proposed Rule · Jul 29, 2002

restricted stock, nonstatutory stock options, statutory stock options (incentive stock options described in section 422(b) and options granted under an employee stock purchase plan described in section 423 … Solely for purposes of this paragraph (d)(2)(iii)(A), section 421 does not apply to the transfer of stock pursuant to the exercise of an option that meets the requirements of section 422(a) or 423(a).

Application of the Federal Insurance Contributions Act, Federal Unemployment Tax Act, and Collection of Income Tax at Source to Statutory Stock Options

Federal Register · Proposed Rule · Nov 14, 2001

U.S., 452 U.S. 247 (1981), that the definitions of wages for FICA and income tax withholding purposes were the same. … LoBue, 351 U.S. 243 (1956); Commissioner v. Smith, 324 U.S. 177 (1945).

Information Reporting Requirements Under Internal Revenue Code Section 6039

Federal Register · Rule · Nov 17, 2009

phrase in 6039(a)(2) following the reference to section 423(c)) rather than whether or not the shares are disposed of in a qualifying disposition as also described in 423(c). … These commenters point out that the reported information may not be useful to nonresident aliens because they likely will not have any U.S. tax liability.

Imposition of Accuracy-Related Penalty

Federal Register · Uncategorized Document · Feb 2, 1994

adjustment, unless the treatment of that transaction affects the determination of U.S. source income or taxable income that is effectively connected with the conduct of a trade or business within the … Applying section 482, the IRS disallows a deduction for twenty five million dollars of the interest that CFCI paid to CFC2, which results in CFC1's U.S. shareholder having a subpart F inclusion in excess

Intercompany Transfer Pricing Regulations Under Section 482

Federal Register · Uncategorized Document · Jul 8, 1994

Section 1.482-2 also issued under 26 U.S.C. 482. Section 1.482-3 also issued under 26 U.S.C. 482. Section 1.482-4 also issued under 26 U.S.C. 482. … Section 482 and the regulations thereunder apply to all controlled taxpayers, whether the controlled taxpayer files a separate or consolidated U.S. income tax return.

Revision of Section 482 Cost Sharing Regulations

Federal Register · Rule · May 13, 1996

(i) U.S. … U.S.

Section 482: Methods To Determine Taxable Income in Connection With a Cost Sharing Arrangement

Federal Register · Proposed Rule · Aug 29, 2005

U.S. Parent (USP), a U.S. corporation, and its foreign subsidiary (FS) enter a CSA in Year 1. … (i) U.S.

Source and Grouping Rules for Foreign Sales Corporation Transfer Pricing

Federal Register · Rule · Mar 3, 1998

pricing rule of section 994(a)(3) corresponds to the section 482 pricing rule of section 925(a)(3). … Under section 863(b), the $50 income allocated to the DISC's related supplier would be sourced $25 U.S. source and $25 foreign source.

Computation of Combined Taxable Income Under The Profit Split Method When the Possession Product is a Component Product or an End- Product Form for Purposes of the Possessions Credit Under Section 936

Federal Register · Rule · May 10, 1996

S obtains a component from a U.S. affiliate, O. S sells its production to another U.S. affiliate, P, which incorporates the microprocessors into central processing units (CPUs). … Taxpayer manufactures product A in a U.S. possession.

Clarification of the Coordination of the Transfer Pricing Rules With Other Code Provisions

Federal Register · Rule · Sep 16, 2015

Under the CSA, P is entitled to the U.S. rights to conduct the Business, and S1 is entitled to the rest-of-the-world (“ROW”) rights to conduct the Business. … P takes the position that the only platform contribution transactions (“PCTs”) in connection with the Date Y CSA consist of P's contribution of the U.S.

Treatment of Services Under Section 482; Allocation of Income and Deductions From Intangibles; Stewardship Expense

Federal Register · Rule · Aug 4, 2006

FP's wholly-owned, exclusive U.S. distributor, USSub, sells Product X in the U.S. market. USSub hires an independent marketing firm, Agency A, to promote Product X in the U.S. market. … USSub is FP's wholly-owned subsidiary in the U.S. market and the exclusive U.S. distributor of FP's merchandise.

Source Rules for Foreign Sales Corporation Transfer Pricing

Federal Register · Rule · Sep 21, 1998

pricing rule of section 994(a)(3) corresponds to the section 482 pricing rule of section 925(a)(3). … Under section 863(b), the $50 income allocated to the DISC's related supplier would be sourced $25 U.S. source and $25 foreign source.

Treatment of Services Under Section 482; Allocation of Income and Deductions From Intangibles; Stewardship Expense; Correction

Federal Register · Rule · Dec 22, 2006

(i) * * * (vi) In contrast, if aggregated services AB were allocated by reference to the total U.S. dollar value of sales to uncontrolled parties (trade sales) by each company, the following results would … Section 1.6662-6T is amended by revising paragraph (d)(2)(ii)(B), first sentence to read as follows: § 1.6662-6T Transactions between parties described in section 482 and net section 482 transfer

Section 482: Methods To Determine Taxable Income in Connection With a Cost Sharing Arrangement

Federal Register · Proposed Rule · Jan 5, 2009

The temporary regulations provide guidance regarding methods under section 482 to determine taxable income in connection with a cost sharing arrangement. … This certification is based on the fact that this rule applies to U.S. businesses and foreign affiliates that enter into cost sharing agreements.

Section 6662Imposition of the Accuracy-Related Penalty

Federal Register · Rule · Feb 9, 1996

Applying section 482, the IRS disallows a deduction for 25 million dollars of the interest that CFC1 paid to CFC2, which results in CFC1's U.S. shareholder having a subpart F inclusion in excess of five … section 482 arm's length result

Treatment of Services Under Section 482; Allocation of Income and Deductions From Intangibles

Federal Register · Proposed Rule · Sep 10, 2003

In Year 1, FP enters the U.S. market by selling YY wristwatches to its newly organized U.S. subsidiary, USSub, for distribution in the U.S. market. … in the U.S. market.

Treatment of Certain Transfers of Property to Foreign Corporations

Federal Register · Proposed Rule · Sep 16, 2015

Coordination with Section 482 The temporary regulations under section 482 published in the Rules and Regulations section of this issue of the Federal Register clarify the coordination of the application … in accordance with section 482 and the regulations thereunder

Section 482: Methods To Determine Taxable Income in Connection With a Cost Sharing Arrangement

Federal Register · Rule · Jan 5, 2009

(i) U.S. … The addition reads as follows: § 1.6662-6 Transaction between persons described in section 482 and net section 482 transfer price adjustments.

Notice of Certain Transfers to Foreign Partnerships and Foreign Corporations

Federal Register · Rule · Feb 5, 1999

Deemed contributions resulting from IRS- initiated section 482 adjustments are not required to be reported under section 6038B. … A taxpayer-initiated adjustment is a section 482 adjustment that is made by the taxpayer pursuant to Sec. 1.482-1(a)(3). (7) United States person.