Documents

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).

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.

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.

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.

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.

Agency Information Collection Activities; Submission for OMB Review; Comment Request; Multiple IRS Information Collection Requests

Federal Register · Notice · Mar 27, 2018

Title: Methods to Determine Taxable Income in connection with a Cost Sharing Arrangement—IRC Section 482. OMB Control Number: 1545-1364. … IRC section 482 places a controlled taxpayer on tax parity with an uncontrolled taxpayer by determining true taxable income.

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.

Notice of Revised Time Frames Regarding Test of Reconciliation for Adjustments Made to the Price of Imported Merchandise by Related Party Companies Under 26 U.S.C. 482

Federal Register · Notice · Dec 15, 1995

AGENCY: U.S. … Matthew Krimski, Office of Regulatory Audit, Office of Strategic Trade, U.S. Customs Service, 1301 Constitution Avenue, N.W., Washington, D.C. 20229.

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 Cost Sharing Regulations

Federal Register · Rule · Dec 20, 1995

(i) U.S. … U.S.

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 Issuance of Final Determination Concerning Auto/Marine Adapters

Federal Register · Notice · Mar 2, 1995

Customs Service, Franklin Court, 1301 Constitution Avenue, NW., Washington, DC 20229; (202) 482-6906. FOR FURTHER INFORMATION CONTACT: Anthony A. … Tonucci, Attorney-Advisor, Office of Regulations and Rulings, (202) 482-7073.

Distribution of Continued Dumping and Subsidy Offset to Affected Domestic Producers

Federal Register · Notice · Aug 3, 2001

A-423-602 731-TA-365 Industrial phosphoric acid/Belgium Albright & Wilson, FMC, Hydrite Chemical, Monsanto, Stauffer Chemical. … C-423-809 701-TA-376 Stainless steel plate in coils/Belgium Armco Steel, Lukens Steel, United Steelworkers of America.

Privacy Act of 1974, as Amended: System of Records

Federal Register · Notice · Oct 18, 2001

Customs Service, 423 Canal Street, New Orleans, LA 70130. … SYSTEM LOCATION: Financial Management Division, U.S. Customs Service, Gulf Customs Management Center, 423 Canal Street, New Orleans, LA 70130.

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.