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Briefs, oral arguments, agency decisions and the Federal Register.
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A Comprehensive Strategy for Reducing the Tax Gap
Agency decision · Agency decision
A Comprehensive Strategy for Reducing the Tax Gap U.S. … A representative sample of these items includes: • Guidance regarding transfer-pricing arrangements involving cost-sharing under section 482; • Guidance under section 671 regarding information reporting
Internal Revenue ServiceAgency decision · Agency decision
Section 482.—Allocation of Income and Deductions Among Taxpayers Section 483. … PO—Possession of the U.S. PR—Partner. PRS—Partnership. i PTE—Prohibited Transaction Exemption. Pub. L.—Public Law. REIT—Real Estate Investment Trust. Rev. Proc.—Revenue Procedure. Rev. Rul.
Internal Revenue ServiceAgency decision · Agency decision
.— Determination of Issue Price in the Case of Certain Debt Instruments Issued for Property (Also Sections 42, 280G, 382, 467, 468, 482, 483, 1288, 7520, 7872.) Rev. … The notice that must be submitted to DOL should be sent to the following address: U.S.
Internal Revenue ServiceAgency decision · Agency decision
.— Determination of Issue Price in the Case of Certain Debt Instruments Issued for Property (Also Sections 42, 280G, 382, 467, 468, 482, 483, 1288, 7520, 7872.) Rev. … The security-required person must enter into a binding agreement with a U.S. agent (as defined in paragraph (d)(4)(ii)(D) of this section) authorizing the U.S. agent to act as an agent (U.S. agent agreement
Internal Revenue ServiceA History of the Tax-Exempt Sector:
Agency decision · Agency decision
NOTES: Data were adjusted based on the chain-type price index for Gross Domestic Product as reported by the U.S. … 1998 46,208 7,585 6,484 1,100 1,670 569 506 464 1999 42,151 7,722 6,835 887 1,485 598 423 422 2000 38,567 8,413 7,703 710 1,427 717 406 403 2001 35,540 7,900 7,883 18
Internal Revenue ServiceTrends in Book-Tax Income and Balance Sheet Differences
Agency decision · Agency decision
The U.S. … Resources Comm., Tech. & Media Total 5,552 4,379 7,849 6,361 3,890 28,031 1990 262 342 304 258 231 1,397 1991 291 375 486 437 306 1,895 1992 314 393 539 498 328 2,072 1993 561 423
Internal Revenue ServiceAgency decision · Agency decision
.— Determination of Issue Price in the Case of Certain Debt Instruments Issued for Property (Also Sections 42, 280G, 382, 467, 468, 482, 483, 1288, 7520, 7872.) Rev. … Section 482.—Allocation of Income and Deductions Among Taxpayers The applicable federal short-term, mid-term, and long-term rates are set forth for the month of August 2025. See Rev.
Internal Revenue ServiceThese synopses are intended only as aids to the reader in
Agency decision · Agency decision
For sale by the Superintendent of Documents, U.S. Government Printing Office, Washington, DC 20402. 2000–9 I.R.B. … 311 353 394 437 480 521 564 606 648 690 763 869 975 1,080 1,237 1,449 1,660 1,870 2,080 2,292 2,503 2,713 2,923 3,134 3,346 3,556 3,766 3,977 4,189 32 57 82 107 133 157 183 209 234 259 284 310 335 373 423
Internal Revenue ServiceAgency decision · Agency decision
Enter the U.S. … Enter 50% of the freight expenses (except insurance) for shipping export property aboard U.S. flagships and U.S.-owned and U.S.
Internal Revenue ServicePrivateFoundationsandCharitableTrusts,1996
Agency decision · Agency decision
In addition to domestic foundations, foreign organizations receiving certain degrees of support from U.S. citizens or corporations must also file Form 990-PF. … Like domestic foundations, organizations based in foreign countries are required to pay excise tax on their net investment income from U.S. sources.
Internal Revenue ServiceAgency decision · Agency decision
.— Determination of Issue Price in the Case of Certain Debt Instruments Issued for Property (Also Sections 42, 280G, 382, 467, 468, 482, 483, 1288, 7520, 7872.) Rev. … PO—Possession of the U.S. PR—Partner. PRS—Partnership. i PTE—Prohibited Transaction Exemption. Pub. L.—Public Law. REIT—Real Estate Investment Trust. Rev. Proc.—Revenue Procedure. Rev. Rul.
Internal Revenue ServiceAgency decision · Agency decision
Section 482.—Allocation of Income and Deductions Among Taxpayers sections 382, 1274, 1288, and other sections of the Code, tables set forth the rates for September 2001. … —Determination of Issue Price in the Case of Certain Debt Instruments Issued for Property (Also Sections 42, 280G, 382, 412, 467, 468, 482, 483, 642, 807, 846, 1288, 7520, 7872.)
Internal Revenue ServiceAgency decision · Agency decision
Section 482.—Allocation of Income and Deductions Among Taxpayers Federal short-term, mid-term, and long-term rates are set forth for the month of November 1997. See Rev. Rul. 97–44, page 5. … —Determination of Issue Price in the Case of Certain Debt Instruments Issued for Property (Also Sections 42, 280G, 382, 412, 467, 468, 482, 483, 642, 807, 846, 1288, 7520, 7872.)
Internal Revenue ServiceAgency decision · Agency decision
.— Determination of Issue Price in the Case of Certain Debt Instruments Issued for Property (Also, Sections 42, 280G, 382, 467, 468, 482, 483, 1288, 7520, 7872.) Rev. … PO—Possession of the U.S. PR—Partner. PRS—Partnership. i PTE—Prohibited Transaction Exemption. Pub. L.—Public Law. REIT—Real Estate Investment Trust. Rev. Proc.—Revenue Procedure. Rev. Rul.
Internal Revenue ServiceAgency decision · Agency decision
.— Determination of Issue Price in the Case of Certain Debt Instruments Issued for Property (Also, Sections 42, 280G, 382, 467, 468, 482, 483, 1288, 7520, 7872.) Rev. … Section 1.6050K-1(f)(1) requires a partnership to file Form 8308 as an attachment to its Form 1065, U.S.
Internal Revenue ServiceAgency decision · Agency decision
Manufactured Product’s manufacturer to produce the U.S. Manufactured Product or by the Non-U.S. Manufactured Product’s manufacturer to produce or acquire the U.S. Component. … For purposes of this notice, the manufacturer of a U.S. Manufactured Product or a Non-U.S. Manufactured Product is the person that performed the manufacturing process that produced the U.S.
Internal Revenue ServiceSEQ 0001 JOB D37-001-005 PAGE-0003 COVER
Agency decision · Agency decision
Under paragraph (e)(2), income reallocated under section 482 from a U.S. person to a related foreign person would be considered a payment for withholding tax purposes. … Further, income arising as a result of a secondary adjustment made in conjunction with a reallocation of income under section 482 from a foreign person to a related U.S. person is considered paid to a
Internal Revenue ServiceAgency decision · Agency decision
Effective Date Upon signature by the U.S. and Danish competent authorities, this Arrangement is effective for dividends paid on or after February 1, 2008. … -10, 2025-19 I.R.B. 1421 2025-11, 2025-23 I.R.B. 1451 2025-12, 2025-23 I.R.B. 1471 Treasury Decisions: 10016, 2025-3 I.R.B. 313 10020, 2025-3 I.R.B. 408 10018, 2025-4 I.R.B. 446 10019, 2025-4 I.R.B. 482
Internal Revenue ServiceSole Proprietorship Returns, 2012
Agency decision · Agency decision
See U.S. Department of Commerce, Bureau of Economic Analysis, Survey of Current Business. … Constant dollars are based on the overall implicit price deflator for gross domestic product computed and reported by the U.S.
Internal Revenue ServiceAgency decision · Agency decision
PO—Possession of the U.S. PR—Partner. PRS—Partnership. i PTE—Prohibited Transaction Exemption. Pub. L.—Public Law. REIT—Real Estate Investment Trust. Rev. Proc.—Revenue Procedure. Rev. Rul. … , 2023-23 I.R.B. 905 2023-43, 2023-24 I.R.B. 919 9970, 2023-2 I.R.B. 311 9771, 2023-3 I.R.B. 346 9772, 2023-11 I.R.B. 530 9773, 2023-11 I.R.B. 557 Proposed Regulations: REG-100442-22, 2023-3 I.R.B. 423
Internal Revenue Service
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