Works matching DE "CONTROLLED foreign corporations"
Results: 121
X‐GmbH v Finanzamt Stuttgart – Körperschaften: Abuse of Tax Law and Exchange of Tax Information in EU law.
- Published in:
- Modern Law Review, 2022, v. 85, n. 2, p. 488, doi. 10.1111/1468-2230.12665
- Publication type:
- Article
KONTROL EDİLEN YABANCI KURUM KAZANCININ ZARARLI VERGİ REKABETİNE ETKİSİ.
- Published in:
- Financial Analysis / Mali Cozum Dergisi, 2013, n. 119, p. 163
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- Publication type:
- Article
Global View: How to Elect Code Sec. 962 Treatment: New Uses for an Old Tool?
- Published in:
- Journal of Tax Practice & Procedure, 2018, v. 20, n. 6, p. 11
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- Publication type:
- Article
The taxation of controlled foreign corporations: An international comparison.
- Published in:
- 1987
- Publication type:
- Book Review
Ireland's Foreign-Owned Technology Sector: Evolving Towards Sustainability?
- Published in:
- Growth & Change, 2008, v. 39, n. 3, p. 436, doi. 10.1111/j.1468-2257.2008.00433.x
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- Publication type:
- Article
Section 1248(b): The individual Limitation on Taxing Sales of CGC Stock Offers Substantial Tax Savings.
- Published in:
- Journal of the American Taxation Association, 1981, v. 2, n. 2, p. 20
- By:
- Publication type:
- Article
International Tax Issues Corner Regulations Focus on U.S. Property Held by CFCS in Partnership Transactions.
- Published in:
- Journal of Passthrough Entities, 2017, v. 20, n. 1, p. 11
- By:
- Publication type:
- Article
International Tax Issues Corner.
- Published in:
- Journal of Passthrough Entities, 2014, v. 17, n. 4, p. 21
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- Publication type:
- Article
International Tax Issues Corner.
- Published in:
- Journal of Passthrough Entities, 2014, v. 17, n. 3, p. 13
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- Article
International Tax Issues Corner.
- Published in:
- Journal of Passthrough Entities, 2013, v. 16, n. 5, p. 13
- By:
- Publication type:
- Article
International Tax Issues Corner.
- Published in:
- Journal of Passthrough Entities, 2011, v. 14, n. 3, p. 13
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- Publication type:
- Article
International Tax Issues Corner.
- Published in:
- Journal of Passthrough Entities, 2009, v. 12, n. 4, p. 13
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- Publication type:
- Article
International Tax Issues Corner.
- Published in:
- Journal of Passthrough Entities, 2009, v. 12, n. 2, p. 27
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- Publication type:
- Article
Notice 2008-91, Treatment of Certain CFC Obligations under Section 956 of the Internal Revenue Code.
- Published in:
- Tax Executive, 2008, v. 60, n. 6, p. 453
- Publication type:
- Article
Virtual Manufacturing and the Proposed Contract Manufacturing Regulations.
- Published in:
- Tax Executive, 2008, v. 60, n. 4, p. 255
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- Publication type:
- Article
Repatriation Guidance -- Part 2: Notice 2005-38 Clarifies Critical Issues.
- Published in:
- Tax Executive, 2005, v. 57, n. 3, p. 252
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- Publication type:
- Article
Microsoft's Foreign Earnings: Tax Strategy.
- Published in:
- Issues in Accounting Education, 2015, v. 30, n. 4, p. 297, doi. 10.2308/iace-51177
- By:
- Publication type:
- Article
INTERNATIONAL REDEPLOYMENT OF MANAGEMENT PERSONNEL.
- Published in:
- International Journal of Business Insights & Transformation, 2008, v. 1, n. 2, p. 1
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- Publication type:
- Article
IMPLEMENTING GLOBAL STRATEGIES: THE ROLE OF PROCEDURAL JUSTICE.
- Published in:
- Strategic Management Journal (John Wiley & Sons, Inc.) - 1980 to 2009, 1991, v. 12, p. 125, doi. 10.1002/smj.4250120910
- By:
- Publication type:
- Article
Technological Change: Disaggregation and Overseas Production.
- Published in:
- Journal of Economic Issues, 1988, v. 22, n. 2, p. 469, doi. 10.1080/00213624.1988.11504777
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- Publication type:
- Article
Chairman Camp's Proposal to Bring the Money Home.
- Published in:
- Financial Executive, 2012, v. 28, n. 2, p. 18
- Publication type:
- Article
New Tax Legislation Consequences on U.S. Transfer Pricing and Intangibles.
- Published in:
- Value Examiner, 2018, p. 15
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- Publication type:
- Article
Joined Cases C-443/14 and C-444/14 Kreis Warendorf v Ibrahim Alo and Amira Osso v Region Hannover (Judgment of the Court of Justice, Grand Chamber, 1 March 2016).
- Published in:
- International Journal of Refugee Law, 2016, v. 28, n. 3, p. 493, doi. 10.1093/ijrl/eew052
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- Publication type:
- Article
IDENTITY, COMMUNITY, AND AUDIENCE: HOW WHOLLY OWNED FOREIGN SUBSIDIARIES GAIN LEGITIMACY IN CHINA.
- Published in:
- Academy of Management Journal, 2007, v. 50, n. 1, p. 175, doi. 10.5465/AMJ.2007.24162209
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- Publication type:
- Article
International Tax Controversies.
- Published in:
- Journal of Taxation of Global Transactions, 2006, v. 6, n. 3, p. 23
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- Publication type:
- Article
The Impact of Code Sec. 951(a)(2)(B) on Subpart F.
- Published in:
- Journal of Taxation of Global Transactions, 2006, v. 6, n. 3, p. 51
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- Publication type:
- Article
A Note From the Editor-in-Chief.
- Published in:
- Journal of Taxation of Global Transactions, 2006, v. 6, n. 3, p. 3
- By:
- Publication type:
- Article
On Jabberwocky, Tumtum Trees and the Active Financing Exception to Subpart F.
- Published in:
- Journal of Taxation of Financial Products, 2008, v. 7, n. 2, p. 25
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- Publication type:
- Article
Reframing the Questions Surrounding the Application of Code Sec. 245A to Controlled Foreign Corporations.
- Published in:
- International Tax Journal, 2025, v. 51, n. 1, p. 22
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- Publication type:
- Article
Testing PFIC Status: Recent Regulations Raise Traps for the Unwary in Applying the Asset Test Rules.
- Published in:
- International Tax Journal, 2024, v. 50, n. 5, p. 6
- By:
- Publication type:
- Article
Claiming Foreign Tax Credits Arising from Never-Ending Foreign Audits--An Overview.
- Published in:
- International Tax Journal, 2024, v. 50, n. 5, p. 3
- By:
- Publication type:
- Article
What Limitations Apply to the CAMT Foreign Tax Credit?
- Published in:
- International Tax Journal, 2024, v. 50, n. 3, p. 18
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- Publication type:
- Article
Code Sec. 961 Basis in Inbound Nonrecognition Transactions.
- Published in:
- International Tax Journal, 2024, v. 50, n. 2, p. 3
- By:
- Publication type:
- Article
Blurry Views from the Look-Through Glass: Application of Code Sec. 954(c)(6) to Payments Out of High-Taxed Earnings and to Payments from Faux CFCs.
- Published in:
- International Tax Journal, 2024, v. 50, n. 1, p. 7
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- Publication type:
- Article
Reconsidering the PFIC Asset Test Adjusted-Basis Requirement's Application to CFCs Held by Domestic Partnerships.
- Published in:
- International Tax Journal, 2023, v. 49, n. 3, p. 11
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- Publication type:
- Article
IRS Proposes Further Limits on the "Pro Rata Share" Rule of Code Sec. 951(a)(2)(B).
- Published in:
- International Tax Journal, 2023, v. 49, n. 1, p. 5
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- Publication type:
- Article
Recent IRS Ruling on a Mid-Year PTEP Distribution.
- Published in:
- International Tax Journal, 2023, v. 49, n. 1, p. 3
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- Publication type:
- Article
Treatment of Foreign Stock and Debt Losses: Is It a Total Loss?
- Published in:
- International Tax Journal, 2022, v. 48, n. 6, p. 5
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- Publication type:
- Article
The Elusive Nature of Code Sec. 961(c) Basis in a Post-TCJA Multiverse.
- Published in:
- International Tax Journal, 2022, v. 48, n. 5, p. 47
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- Publication type:
- Article
No One Is Doing Inversions Anymore, So Why Does Code Sec. 7874 Apply to My Deal?
- Published in:
- International Tax Journal, 2022, v. 48, n. 4, p. 23
- By:
- Publication type:
- Article
The All Earnings and Profits Amount of a Domesticating Foreign Target: The Non-Recognition Cleansing Exception.
- Published in:
- International Tax Journal, 2022, v. 48, n. 3, p. 5
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- Publication type:
- Article
Important Subpart F and PFIC Changes for U.S. Investors and Domestic Funds.
- Published in:
- International Tax Journal, 2022, v. 48, n. 2, p. 45
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- Publication type:
- Article
More Anti-Abuse Tools as Dutch Government Announces Strengthening the CFC Rule.
- Published in:
- International Tax Journal, 2022, v. 48, n. 1, p. 31
- By:
- Publication type:
- Article
Start with When: Navigating When (and by Whom) Foreign Income Taxes Accrue for Purposes of the U.S. Foreign Tax Credit Rules.
- Published in:
- International Tax Journal, 2022, v. 48, n. 1, p. 19
- By:
- Publication type:
- Article
Apportionment of the Interest Expense of Partnerships and Partners.
- Published in:
- International Tax Journal, 2022, v. 48, n. 1, p. 7
- By:
- Publication type:
- Article
The Phoenix Rises--Code Sec. 962 Election Is Back in Vogue.
- Published in:
- International Tax Journal, 2021, v. 47, n. 6, p. 7
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- Publication type:
- Article
The Final Code Sec. 267A Regulations and Payments by CFCs.
- Published in:
- International Tax Journal, 2021, v. 47, n. 5, p. 25
- By:
- Publication type:
- Article
Taxable Acquisitions of Foreign Corporations During a Pandemic (of Change).
- Published in:
- International Tax Journal, 2021, v. 47, n. 5, p. 7
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- Publication type:
- Article
Debt Push Downs and the Curious Application of the Debt-Netting Rule.
- Published in:
- International Tax Journal, 2021, v. 47, n. 3, p. 7
- By:
- Publication type:
- Article
The Benefits of Subpart F Income.
- Published in:
- International Tax Journal, 2021, v. 47, n. 3, p. 5
- By:
- Publication type:
- Article