47 results on '"Renfroe, Diane L."'
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2. The final withholding regulations: a Rube Goldberg contraption - will it work?
3. Current status of U.S. tax treaties.
4. Section 894: payments to flow-through entities.
5. Current status of U.S. tax treaties.
6. The proposed section 1441 withholding rules; daughter of portfolio interest.
7. The proposed regulations for allocation and apportionment of research and experimental expenditures - 'and the beat goes on....'
8. Current status of U.S. tax treaties.
9. St. Jude, Perkin-Elmer and the allocation of research and experimental expenditures.
10. Current status of U.S. tax treaties.
11. The new section 904(i) regulations: short but not sweet.
12. Current status of U.S. tax treaties.
13. The international provisions of the Revenue Reconciliation Act of 1993.
14. Allocation and apportionment of research and experimental (R&E) expenditures: the percentage game or passing the buck.
15. Unpleasant surprises: life in the section 1291 ditch.
16. Earnings stripping: an analysis of the proposed regulations under section 163(j).
17. Current status of U.S. tax treaties.
18. Current status of U.S. tax treaties.
19. Information reporting for foreign-owned corporations (the proposed section 6038A regulations) - the inside story.
20. Rev. Rul. 90-76 closes loophole in the temporary FIRPTA regulations concerning distributions of USRPI.
21. Current status of U.S. tax treaties.
22. Taxing foreign investors' stock sale gains, round 2: an idea whose time has come too fast?
23. Distributive share of foreign partnership income held not subpart F income.
24. Interest paid to a foreign subsidiary of a foreign leasing company involved in commercial lending qualifies as portfolio interest.
25. Current status of U.S. tax treaties.
26. Impact of new Antilles treaty and proposed U.S. law changes on current FIRPTA structures.
27. 1989 tax bill: taxing foreign investors on capital gains.
28. Highlights of the new temporary and final FIRPTA withholding regulations.
29. Proposed s. 904(f) regulations: major policy issues and their resolution.
30. FIRPTA - security agreements - Rev. Proc. 85-41 revisited.
31. Is the benefit of the U.S.-Netherlands Antilles Treaty terminated for financing companies?
32. An analysis of new Section 1445 (FIRPTA withholding) - problem areas and strategies.
33. Stapled stock - analysis of new Section 269B as it affects U.S. and foreign stapled entities.
34. Withholding obligations of partnerships: ss. 1441-1446.
35. Statutory domestications treated as 'F' reorganizations: more than a 'mere change.'
36. Revisions to income-sourcing rules likely to increase U.S. tax on foreign income: exceptions to the revised sourcing rules provide a number of planning opportunities, but use the 80-20 provisions has been restricted.
37. Inordinate recordkeeping needed to allocate and apportion interest under prop. regs.: the new rules require that more interest expense be allocated to foreign-source income, effectively reducing the benefit of foreign tax credits.
38. Use of foreign sales corporations enhanced by approach of Temp. Regs.
39. Key interpretative issues under the proposed Section 911 regulations.
40. International implications of a cash flow consumption tax.
41. U.S.-Canada income tax treaty requires income of U.S. branch to be determined under facts and circumstances.
42. FTC carryback eliminates interest on earlier underpayment of tax.
43. Do the section 6038A recordkeeping rules violate treaty nondiscrimination clauses?
44. Current status of U.S. tax treaties.
45. Status of U.S. tax treaties.
46. New regulations affect investments in U.S. property and related party stock sales.
47. FTC carryback eliminates interest on earlier underpayment of tax.
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