Documents

Briefs, oral arguments, agency decisions and the Federal Register.

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  • 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

    Treasury DepartmentInternal Revenue Service
  • Imposition of Accuracy-Related Penalty

    Federal Register · Uncategorized Document · Jul 8, 1994

    * * * * * Section 1.6662-6T Transactions between persons described in section 482 and net section 482 transfer price adjustments (temporary). … The additions and revisions read as follows: Section 1.6662-6T Transactions between persons described in section 482 and net section 482 transfer price adjustments (temporary).

    Treasury Department
  • 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.

    Treasury DepartmentInternal Revenue Service
  • Examination of Baggage

    Federal Register · Uncategorized Document · Nov 10, 1994

    FOR FURTHER INFORMATION CONTACT: Lars-Erik Hjelm, Office of the Chief Counsel, U.S. Customs Service, 202-927-6900. … The primary provisions are sections 482, 1461, 1462, 1496, 1581 and 1582 of Title 19, United States Code (19 U.S.C. 482, 1461, 1462, 1496, 1581, and 1582).

    Treasury DepartmentCustoms Service
  • Public Meeting on Customs ``Mod Act''

    Federal Register · Uncategorized Document · Feb 24, 1994

    Phone: (202) 482-6990; FAX: (202) 482-6994. SUPPLEMENTARY INFORMATION: On December 8, 1993, the President signed the ``North American Free Trade Agreement Implementation Act.'' … Dale Snell at 202-482-6994. Individuals not having access to facsimile equipment may pre-register by calling Mr. Snell at 202-482-6990.

    Treasury DepartmentCustoms Service
  • Public Meeting on Customs ``Mod Act''

    Federal Register · Uncategorized Document · Jan 18, 1994

    Phone: (202) 482-6990; FAX: (202) 482-6994. SUPPLEMENTARY INFORMATION: On December 8, 1993, the President signed the ``North American Free Trade Agreement Implementation Act.'' … Dale Snell by FAX at 202-482-6994 or by phone at 202-482-6990. Should demand for seats exceed capacity, Customs will schedule and hold a second meeting with an identical agenda.

    Treasury DepartmentCustoms Service
  • Receipt of Domestic Interested Party Petition Concerning Country of Origin Marking for Cast Iron Soil Pipe

    Federal Register · Uncategorized Document · Mar 8, 1994

    Robert Dinerstein, Value and Marking Branch, Office of Regulations and Rulings, U.S. Customs Service (202) 482-7010. … Appointments to inspect the petition and comments can be made by contacting the Regulations Branch at 202-482-6970.

    Treasury DepartmentCustoms Service
  • Computation of Combined Taxable Income Under the Profit Split Method When the Possession Product Is a Component Product or an End- Product Form

    Federal Register · Uncategorized Document · Jan 12, 1994

    The proposed change is intended to simplify the computation of combined taxable income under Q & A. 12 and to eliminate the need to apply section 482 in cases in which a possession product is a component … -- (A) First, to U.S. affiliates (other than tax-exempt affiliates) within the group (as determined under section 482) which derive income with respect to the product produced in whole or in part in

    Treasury DepartmentInternal Revenue Service
  • Recordation of Trade Name: ``PresenTense''

    Federal Register · Uncategorized Document · May 2, 1994

    DEPARTMENT OF THE TREASURY Customs Service [T.D. 94-43] Recordation of Trade Name: ``PresenTense'' AGENCY: U.S. Customs Service, Department of the Treasury. … Cooper, Intellectual Property Rights Branch, 1301 Constitution Avenue NW., (Franklin Court), Washington, DC 20229 (202 482-6960). Dated: April 22, 1994. John F.

    Treasury DepartmentCustoms Service
  • Reporting Requirements for Vessels, Vehicles and Individuals; Correction

    Federal Register · Uncategorized Document · Jan 13, 1994

    DEPARTMENT OF THE TREASURY Customs Service 19 CFR Parts 4 and 123 [T.D. 93-96] RIN 1515-AB31 Reporting Requirements for Vessels, Vehicles and Individuals; Correction AGENCY: U.S. … Burton (202) 482-6940.

    Treasury DepartmentCustoms Service
  • Tariff Classification of Camera Lenses Imported in Same Shipment With Camera Bodies

    Federal Register · Uncategorized Document · Feb 15, 1994

    ADDRESSES: Comments (preferably in triplicate) may be addressed to the Regulations Branch, U.S. … Spence, Office of Regulations and Rulings (202) 482-7030.

    Treasury DepartmentCustoms Service
  • Country of Origin Marking for Packaged Frozen Produce; Suspension of Date for Compliance

    Federal Register · Uncategorized Document · Mar 29, 1994

    FOR FURTHER INFORMATION CONTACT: Robert Cascardo, Value and Marking Branch, Office of Regulations and Rulings, U.S. Customs Service, (202) 482-7010. … Drafting Information The principal drafter of this document was Robert Cascardo, Value and Marking Branch, U.S. Customs Service.

    Treasury DepartmentCustoms Service
  • Application for Recordation of Trade Name: ``Presentense''

    Federal Register · Uncategorized Document · Feb 3, 1994

    ADDRESSES: Written comments should be addressed to U.S. Customs Service, Attention: Intellectual Property Rights Branch, 1301 Constitution Avenue NW. (Franklin Court), Washington, DC 20229. … (Franklin Court), Washington, DC 20229 (202-482-6960). Dated: January 26, 1994. John F. Atwood, Chief, Intellectual Property Rights Branch.

    Treasury Department
  • Recordation of Trade Name: ``Superior Seedless Grape Co.''

    Federal Register · Uncategorized Document · Feb 3, 1994

    AGENCY: U.S. Customs Service, Department of the Treasury. … Cooper, Intellectual Property Rights Branch, 1301 Constitution Avenue NW., (Franklin Court), Washington, DC 20229 (202 482-6960). Dated: January 26, 1994. John F.

    Treasury Department
  • Technical Corrections to the Customs Regulations Relating to Customs Modernization

    Federal Register · Uncategorized Document · Mar 21, 1994

    Vilders, Regulations Branch (202) 482-6930. … In title 46 of the U.S.

    Treasury DepartmentCustoms Service
  • Express Consignments; Formal and Informal Entries of Merchandise; Administrative Exemptions

    Federal Register · Uncategorized Document · Aug 23, 1994

    Service 19 CFR Parts 10, 101, 111, 123, 128, 141, 143, 145, 148, 159 [T.D. 94-71] RIN 1515-AB53 Express Consignments; Formal and Informal Entries of Merchandise; Administrative Exemptions AGENCY: U.S … Rosoff, Office of Regulations and Rulings (202) 482-7040. SUPPLEMENTARY INFORMATION: On June 13, 1994, a document was published by U.S.

    Treasury DepartmentCustoms Service
  • Recordation of Trade Name: ``California Silk Collection''

    Federal Register · Uncategorized Document · Feb 3, 1994

    DEPARTMENT OF THE TREASURY Customs Service [T.D. 94-11] Recordation of Trade Name: ``California Silk Collection'' AGENCY: U.S. Customs Service, Department of the Treasury. … (Franklin Court), Washington, DC 20229 (202 482-6960). Dated: January 26, 1994. John F. Atwood, Chief, Intellectual Property Rights Branch.

    Treasury DepartmentCustoms Service
  • Application for Recordation of Trade Name: ``California Hipermart''

    Federal Register · Uncategorized Document · Dec 20, 1994

    ADDRESSES: Written comments should be addressed to U.S. Customs Service, Attention: Intellectual Property Rights Branch, 1301 Constitution Avenue, NW., (Franklin Court), Washington, D.C. 20229. … Cooper, Intellectual Property Rights Branch, 1301 Constitution Avenue, NW., (Franklin Court), Washington D.C. 20229 (202-482-6960). Dated: December 14, 1994. John F.

    Treasury Department
  • Decision Following a Petition by Domestic Interested Parties Concerning the Location and Method of Country of Origin Marking for Imported Cast Iron Soil Pipes; Correction

    Federal Register · Uncategorized Document · Nov 29, 1994

    175 [T.D. 94-88] Decision Following a Petition by Domestic Interested Parties Concerning the Location and Method of Country of Origin Marking for Imported Cast Iron Soil Pipes; Correction AGENCY: U.S … FOR FURTHER INFORMATION CONTACT: Robert Dinerstein, Office of Regulations and Rulings, (202) 482-7010.

    Treasury DepartmentCustoms Service
  • Application for Recordation of Trade Name: ``Chengcorp''

    Federal Register · Uncategorized Document · Dec 20, 1994

    ADDRESSES: Written comments should be addressed to U.S. Customs Service, Attention: Intellectual Property Rights Branch, 1301 Constitution Avenue, NW., (Franklin Court), Washington, D.C. 20229. … Cooper, Intellectual Property Rights Branch, 1301 Constitution Avenue, NW., (Franklin Court), Washington D.C. 20229 (202-482-6960). Dated: December 14, 1994. John F.

    Treasury Department

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