Internal Revenue Cumulative Bulletin, Tema 2Department of the Treasury, Internal Revenue Service, 1972 |
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Página 175
... earnings and profits of Y exceeded the amount of cash paid by Y to A for the X stock . Section 304 ( a ) ( 1 ) of the Internal Revenue Code of 1954 provides that for purposes of section 302 and section 303 of the Code , if one or more ...
... earnings and profits of Y exceeded the amount of cash paid by Y to A for the X stock . Section 304 ( a ) ( 1 ) of the Internal Revenue Code of 1954 provides that for purposes of section 302 and section 303 of the Code , if one or more ...
Página 180
... to its share- holders of all the stock of a controlled corporation , if the transaction is not used principally as a device for the distribution of the earnings and profits of the distributing corporation 180 Section 351.
... to its share- holders of all the stock of a controlled corporation , if the transaction is not used principally as a device for the distribution of the earnings and profits of the distributing corporation 180 Section 351.
Página 181
United States. Internal Revenue Service. distribution of the earnings and profits of the distributing corporation or the controlled corporation or both ( section 355 ( a ) ( 1 ) ( B ) of the Code ) , and the active business requirements ...
United States. Internal Revenue Service. distribution of the earnings and profits of the distributing corporation or the controlled corporation or both ( section 355 ( a ) ( 1 ) ( B ) of the Code ) , and the active business requirements ...
Página 183
... earnings and profits of the transferor corpora- tion as of the close of the date of trans- fer shall be computed by taking into account the amount of earnings and profits properly applicable to the distribution , regardless of whether ...
... earnings and profits of the transferor corpora- tion as of the close of the date of trans- fer shall be computed by taking into account the amount of earnings and profits properly applicable to the distribution , regardless of whether ...
Página 184
... earnings and profits . Accordingly , the receipt of the cash payment in addition to the stock of X results in the ... Profit - sharing , Stock Bonus Plans , etc. Section 401. - Qualified Pension , Profit - Sharing , and Stock Bonus Plans ...
... earnings and profits . Accordingly , the receipt of the cash payment in addition to the stock of X results in the ... Profit - sharing , Stock Bonus Plans , etc. Section 401. - Qualified Pension , Profit - Sharing , and Stock Bonus Plans ...
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adjusted basis adjusted gross income allowance amended amortization ance apply asset guideline class beginning after December benefits carryback cluded Code provides Commissioner compensation computed contract controlled foreign corporation December 31 deduction depreciation depreciation reserve determined Director distribution dividend earnings and profits election employees erty excess excise tax exempt Federal income tax filing firearm foreign corporation foreign income taxes grantor held imposed by section included Income Tax Regulations individual interest Internal Revenue Code Internal Revenue Service manufacturer meaning of section ment organization paragraph payment percent period person placed in service poration purchase pursuant qualify respect retirement Revenue Ruling salvage value section 501 separate return shares spouse standard deduction Stat Subchapter subparagraph Subpart tax imposed Tax Regulations provides tax return taxable income taxable years beginning taxicab taxpayer tion transfer trust United vides vintage account
Pasajes populares
Página 182 - ... a transfer by a corporation of all or a part of its assets to another corporation if immediately after the transfer the transferor or its stockholders or both are in control of the corporation to which the assets are transferred, or (C) a recapitalization, or (D) a mere change in identity, form, or place of organization, however effected. (2) The term "a party to a reorganization...
Página 409 - If any person liable to pay any tax neglects or refuses to pay the same after demand, the amount (including any interest, penalty, additional amount, or addition to such tax, together with any costs that may accrue in addition thereto) shall be a lien in favor of the United States upon all property and rights to property, whether real or personal, belonging to such person.
Página 166 - For the diagnosis, cure, mitigation, treatment, or prevention of disease, or for the purpose of affecting any structure or function of the body (including amounts paid for accident or health insurance) , or (B) For transportation primarily for and essential to medical care referred to in subparagraph (A).
Página 352 - wages" means all remuneration for employment, including the cash value of all remuneration paid in any medium other than cash; except that such term shall not include that part of the remuneration which, after remuneration...
Página 220 - Income although not actually reduced to a taxpayer's possession is constructively received by him in the taxable year during which it is credited to his account, set apart for him, or otherwise made available so that he may draw upon it at any time, or so that he could have drawn upon it during the taxable year if notice of intention to withdraw had been given. However, income is not constructively received if the taxpayer's control of its receipt is subject to substantial limitations or restrictions.
Página 127 - ... (c) LIMITATION ON LOSSES OF INDIVIDUALS.— In the case of an individual, the deduction under subsection (a) shall be limited to— (1) losses incurred in a trade or business...
Página 274 - The income of a nonresident alien individual which consists exclusively of earnings derived from the operation of a ship or ships documented under the laws of a foreign country which grants an equivalent exemption to citizens of the United States and to corporations organized in the United States shall not be included in gross income and shall be exempt from taxation under this chapter.
Página 83 - ... divorced or legally separated from her husband under a decree of divorce or of separate maintenance, periodic payments (whether or not made at regular intervals) received subsequent to such decree in discharge of, or attributable to property transferred (in trust or otherwise) in discharge of, a legal obligation which, because of the marital or family relationship, is imposed upon or incurred by such husband under such decree or under a written instrument incident to such divorce or separation...
Página 183 - If an exchange would be within the provisions of subsection (b), (1), (2), (3), or (5) of this section if it were not for the fact that the property received in exchange consists not only of property permitted by such paragraph to be received without the recognition of gain, but also of other property or money...
Página 417 - If the taxpayer exercised ordinary business care and prudence and was nevertheless unable to file the return within the prescribed time, then the delay is due to a reasonable cause.