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Your search keyword '"Allocation (Taxation) -- Laws, regulations and rules -- Methods"' showing total 7 results
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7 results on '"Allocation (Taxation) -- Laws, regulations and rules -- Methods"'

1. International Tax Watch: Using the Sourcing Rules to Maximize Foreign Tax Credits-A Primer for Sellers of Inventory.

Author

Misey, Robert and Donetti, Neil

Subjects
Tax planning -- Laws, regulations and rules -- Methods, Foreign tax credit -- Laws, regulations and rules, Foreign source income taxation -- Laws, regulations and rules, Allocation (Taxation) -- Laws, regulations and rules -- Methods, Corporate income taxes -- Laws, regulations and rules, Government regulation
Abstract

I. Introduction The Internal Revenue Code taxes U.S. persons on all of their worldwide income, from whatever source derived. (1) This creates a double taxation problem with respect to a [...]

Published
2024

2. Sales Factor Primer.

Author

Schadewald, Michael S.

Subjects
State taxation -- Accounting and auditing -- Laws, regulations and rules, Allocation (Taxation) -- Laws, regulations and rules -- Methods, Sales tax -- Accounting and auditing -- Laws, regulations and rules, Government regulation, Uniform Division of Income for Tax Purposes Act
Abstract

This is the third part of a three-part series of articles that discuss the general rules for computing the sales factor. Part I discussed the types of gross receipts included [...]

Published
2022

3. AGGLOMERATION AND STATE PERSONAL INCOME TAXES: TIME TO APPORTION (WITH CRITICAL COMMENTARY ON NEW HAMPSHIRE'S COMPLAINT AGAINST MASSACHUSETTS).

Author

Shanske, Darien

Subjects
Allocation (Taxation) -- Laws, regulations and rules -- Methods, Interstate commerce -- Laws, regulations and rules, Government regulation, United States Constitution (U.S. Const. art. 1, s. 8, cl. 3)
Abstract

Introduction 949 I. Background 950 A. The Lawsuit: New Hampshire v. Massachusetts 950 B. Agglomeration Economics 951 C. Doctrine 954 II. Mistaken Contentions of New Hampshire and Its Amici 958 [...]

Published
2021

4. The potential for lost benefits of Up-Cs in a Sec. 280E environment.

Author

Egli, Caleb, Loveall, Nila, Claybon, Marc, and Hollinden, Nick

Subjects
Allocation (Taxation) -- Laws, regulations and rules -- Methods, Marijuana industry -- Finance -- Taxation, Capital investments -- Finance -- Taxation, Partnership -- Finance -- Taxation -- Usage, Close corporations -- Finance -- Taxation -- Usage, Government regulation, Company financing, Capital investment, Internal Revenue Code (I.R.C. 280E) (I.R.C. 754) (I.R.C. 743)
Abstract

For entities operating within the cannabis industry, the current regulatory environment presents numerous complexities and challenges, including one of the utmost importance to all business enterprises--obtaining capital for new investment [...]

Published
2021

5. IRS issues prop. regs. on allocation of costs under simplified sec. 263A methods.

Author

Mora, Kristine and Carlton, Brandon Cash

Subjects
Allocation (Accounting) -- Laws, regulations and rules, Allocation (Taxation) -- Laws, regulations and rules -- Methods, Intangible property -- Taxation, Government regulation, Internal Revenue Code (I.R.C. 263A)
Abstract

The IRS has issued proposed regulations (REG-126770-06) on allocating costs to property produced or acquired by a taxpayer for resale. Background Under Sec. 263A, taxpayers must capitalize the direct and [...]

Published
2013

6. Change in accounting method request does not qualify for audit protection.

Author

Rohrs, Jane

Subjects
Tax accounting -- Methods -- Laws, regulations and rules, Tax returns -- Laws, regulations and rules -- Methods, Allocation (Taxation) -- Laws, regulations and rules -- Methods, Tax auditing -- Laws, regulations and rules -- Methods, Government regulation
Abstract

The IRS has ruled in technical advice (TAM 200738014) that a service provider's request for a change in accounting method for mixed service costs does not qualify for audit protection [...]

Published
2008

7. Beware not allocating the GSTT exemption on a gift tax return - a trap for the unwary.

Author

Sherr, Eileen Reichenberg

Subjects
Personal finance -- Methods -- Laws, regulations and rules, Tax accounting -- Laws, regulations and rules -- Methods, Tax exemption -- Accounting and auditing -- Laws, regulations and rules -- Methods, Tax planning -- Methods -- Laws, regulations and rules, Gift tax -- Accounting and auditing -- Methods -- Laws, regulations and rules, Allocation (Taxation) -- Laws, regulations and rules -- Methods, Generation-skipping transfer tax -- Accounting and auditing -- Methods -- Laws, regulations and rules, Government regulation
Abstract

The AICPA Tax Division's Trust, Estate and Gift Tax Committee has focused on a number of problems and concerns with the current generation-skipping transfer tax (GSTT) exemption that may not [...]

Published
1997

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