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- Title
THE TAXATION OF INTERCOMPANY INCOME.
- Authors
MILLER, ROBERT N.
- Abstract
The article analyzes the issues related to the taxation of intercompany income in the U.S. It is stated that, while dealing with the transactions between two corporations which are completely separate with entirely different stockholders controlling the policies of the two corporations, then it is easy to impose tax, as, apart from dividend income, it is safe to treat intercompany income of a corporation as exactly like its other income. However, as stated, problems related to tax treatment arises when a corporation receives income in a transaction with a corporation owned or controlled by substantially the same corporate interest, as then it is difficult to determine whether the transaction is real or artificial like a gift.
- Subjects
UNITED States; INTERCOMPANY transactions; CORPORATE taxes; AMERICAN business enterprises; TAXATION; STOCKHOLDERS; GOVERNMENT revenue; INTERNAL revenue; PUBLIC finance
- Publication
Law & Contemporary Problems, 1940, Vol 7, Issue 2, p301
- ISSN
0023-9186
- Publication type
Article
- DOI
10.2307/1189624