irc section 964 e 4 - EAS

32,300,000 個結果

  1. 26 U.S. Code § 964 - Miscellaneous provisions | U.S.

    https://www.law.cornell.edu/uscode/text/26/964

    2017年12月31日 · Amendment by section 1065(b) of Pub. L. 94–455 applicable to payments described in section 162(c) of this title made more than 30 days after Oct. 4, 1976, see section 1066(b) of Pub. L. 94–455, set out as a note under section 952 of this title.

  2. Sec. 964. Miscellaneous Provisions

    https://irc.bloombergtax.com/public/uscode/doc/irc/section_964

    Miscellaneous Provisions. § 964. Sec. 964. Miscellaneous Provisions. I.R.C. § 964 (a) Earnings And Profits —. Except as provided in section 312 (k) (4), for purposes of this subpart, the …

  3. 26 U.S.C. § 964 - U.S. Code Title 26. Internal Revenue Code § …

    https://codes.findlaw.com/us/title-26-internal-revenue-code/26-usc-sect-964.html

    2018年1月1日 · In determining such earnings and profits, or the deficit in such earnings and profits, the amount of any illegal bribe, kickback, or other payment (within the meaning of …

  4. SECTION 1. OVERVIEW - IRS tax forms

    https://www.irs.gov/pub/irs-drop/n-19-01.pdf · PDF 檔案

    964(e)(4), section 964(e)(4) generally allows a deduction under section 245A with respect to a domestic corporation’s pro rata share of the subpart F income that it includes in gross income …

    • 檔案大小: 85KB
    • 頁面計數: 21

  5. How Sections 245A and 964(e)(4) Coordinate Treatment of …

    https://www.taxnotes.com/tax-notes-today-international/controlled-foreign-corporations...

    2019年8月19日 · Tax Notes is the first source of essential daily news, analysis, and commentary for tax professionals whose success depends on being trusted for their expertise.

  6. 其他人也問了以下問題
    What is IRC Section 901?
    IRC Section 901 generally permits a taxpayer to claim a credit against its regular US tax liability for "income, war profits, and excess profits taxes" paid or accrued during a tax year to any foreign country or US possession.

    Foreign tax credit regulations revamp creditability rules for foreign

    taxnews.ey.com/news/2022-0040-foreign-tax-credit-regul…
    搜尋: What is IRC Section 901?
    What is section 245 of the Internal Revenue Code?
    Section 245 of the Internal Revenue Code is one of the more complicated aspects of international tax — it involves a deduction for dividends received by a corporate shareholder of a foreign corporation.

    A Section 245A Dividends Received Deduction Tax Overview

    www.goldinglawyers.com/section-245a-dividends-receive…
    搜尋: What is section 245 of the Internal Revenue Code?
    What is IRC section 245A(D) ptep?
    IRC Section 245A (d) PTEP is the PTEP of a foreign corporation resulting from (i) a sale or exchange of stock subject to IRC Sections 964 (e) (4) or 1248 for which an IRC Section 245A deduction was allowed; or (ii) a tiered hybrid dividend that gave rise to an income inclusion to a US shareholder.

    Foreign tax credit regulations revamp creditability rules for foreign

    taxnews.ey.com/news/2022-0040-foreign-tax-credit-regul…
    搜尋: What is IRC section 245A(D) ptep?
    意見反應

  7. 26 CFR § 1.964-1 - Determination of the earnings and …

    https://www.law.cornell.edu/cfr/text/26/1.964-1

    (a) (1) In general. For rules for determining the earnings and profits (or deficit in earnings and profits) of a foreign corporation for taxable years beginning before January 1, 1987, for …

  8. Foreign tax credit regulations revamp creditability rules for foreign …

    https://taxnews.ey.com/news/2022-0040-foreign-tax-credit-regulations-revamp...

    IRC Section 245A(d) PTEP is the PTEP of a foreign corporation resulting from (i) a sale or exchange of stock subject to IRC Sections 964(e)(4) or 1248 for which an IRC Section 245A …

  9. A Section 245A Dividends Received Deduction Tax Overview

    https://www.goldinglawyers.com/section-245a-dividends-received-deduction-overview

    Deemed Dividends Under IRC Section 964 IRC Section 964(e) treats as dividends some gains on sales or exchanges of foreign corporation stock by a CFC. § If a CFC sells or exchanges …

  10. International JournalTM - Fenwick & West LLP

    https://assets.fenwick.com/legacy/FenwickDocuments/Bloomberg-Tax... · PDF 檔案

    New 964(e)(4) Finally, the participation exemption of 245A was also extended to sales of lower-tier CFC stock by an upper-tier CFC where the application of 1248 and 964(e) results in a …

  11. The Importance of Determining Accurate Earnings and …

    https://sftaxcounsel.com/the-importance-of-determining-accurate-earnings-and-profits...

    See IRC Sections 312(k)(3)(A); 168(g)(2). It should be apparent by now that E&P is simply an accounting concept designed to better measure a corporation’s true financial results. It is an …



Results by Google, Bing, Duck, Youtube, HotaVN