Section 1248 Attribution Principles (Us Internal Revenue Service Regulation) (Irs) (2018 Edition)

Section 1248 Attribution Principles (Us Internal Revenue Service Regulation) (Irs) (2018 Edition) PDF

Author: The Law The Law Library

Publisher: Createspace Independent Publishing Platform

Published: 2018-11-11

Total Pages: 26

ISBN-13: 9781729728970

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Section 1248 Attribution Principles (US Internal Revenue Service Regulation) (IRS) (2018 Edition) The Law Library presents the complete text of the Section 1248 Attribution Principles (US Internal Revenue Service Regulation) (IRS) (2018 Edition). Updated as of May 29, 2018 This document contains final regulations under section 1248 of the Internal Revenue Code (Code) that provide guidance for determining the earnings and profits attributable to stock of controlled foreign corporations (or former controlled foreign corporations) that are (were) involved in certain nonrecognition transactions. The final regulations are necessary in order to supplement and clarify existing guidance in the regulations under section 1248. The final regulations affect persons subject to the regulations under section 1248, as well as persons to which regulations under other Code provisions, such as section 367(b), apply to the extent that those regulations incorporate the principles of the section 1248 regulations. In addition, the final regulations provide that with respect to the sale by a foreign partnership of the stock of a corporation, the partners in such foreign partnership shall be treated as selling or exchanging their proportionate share of the stock of such corporation for purposes of section 1248. This book contains: - The complete text of the Section 1248 Attribution Principles (US Internal Revenue Service Regulation) (IRS) (2018 Edition) - A table of contents with the page number of each section

Surrogate Foreign Corporations (Us Internal Revenue Service Regulation) (Irs) (2018 Edition)

Surrogate Foreign Corporations (Us Internal Revenue Service Regulation) (Irs) (2018 Edition) PDF

Author: The Law The Law Library

Publisher: Createspace Independent Publishing Platform

Published: 2018-11-12

Total Pages: 34

ISBN-13: 9781729734568

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Surrogate Foreign Corporations (US Internal Revenue Service Regulation) (IRS) (2018 Edition) The Law Library presents the complete text of the Surrogate Foreign Corporations (US Internal Revenue Service Regulation) (IRS) (2018 Edition). Updated as of May 29, 2018 This document contains final regulations regarding whether a foreign corporation is treated as a surrogate foreign corporation. The final regulations affect certain domestic corporations and partnerships (and certain parties related thereto), and foreign corporations that acquire substantially all of the properties of such domestic corporations or partnerships. This book contains: - The complete text of the Surrogate Foreign Corporations (US Internal Revenue Service Regulation) (IRS) (2018 Edition) - A table of contents with the page number of each section

Taxation of International Transactions

Taxation of International Transactions PDF

Author: Charles H. Gustafson

Publisher: West Academic Publishing

Published: 2011

Total Pages: 0

ISBN-13: 9780314911711

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Designed for use in law schools, business schools and schools of management, this casebook outlines the determination and administration of U.S. income tax liabilities resulting from international transactions. Textual discussion, cases, rulings and problems, guides students through the basic tax considerations that confront foreign individuals and entities participating in the U.S. economy, and U.S. individuals and entities seeking to derive income abroad. Covers both the U.S. tax rules applicable to international transactions and the tax policy considerations underlying those rules.

Mergers, Acquisitions, and Corporate Restructurings

Mergers, Acquisitions, and Corporate Restructurings PDF

Author: Patrick A. Gaughan

Publisher: John Wiley & Sons

Published: 2017-11-27

Total Pages: 676

ISBN-13: 1119380758

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The essential M&A primer, updated with the latest research and statistics Mergers, Acquisitions, and Corporate Restructurings provides a comprehensive look at the field's growth and development, and places M&As in realistic context amidst changing trends, legislation, and global perspectives. All-inclusive coverage merges expert discussion with extensive graphs, research, and case studies to show how M&As can be used successfully, how each form works, and how they are governed by the laws of major countries. Strategies and motives are carefully analyzed alongside legalities each step of the way, and specific techniques are dissected to provide deep insight into real-world operations. This new seventh edition has been revised to improve clarity and approachability, and features the latest research and data to provide the most accurate assessment of the current M&A landscape. Ancillary materials include PowerPoint slides, a sample syllabus, and a test bank to facilitate training and streamline comprehension. As the global economy slows, merger and acquisition activity is expected to increase. This book provides an M&A primer for business executives and financial managers seeking a deeper understanding of how corporate restructuring can work for their companies. Understand the many forms of M&As, and the laws that govern them Learn the offensive and defensive techniques used during hostile acquisitions Delve into the strategies and motives that inspire M&As Access the latest data, research, and case studies on private equity, ethics, corporate governance, and more From large megadeals to various forms of downsizing, a full range of restructuring practices are currently being used to revitalize and supercharge companies around the world. Mergers, Acquisitions, and Corporate Restructurings is an essential resource for executives needing to quickly get up to date to plan their own company's next moves.

Google Earth Engine Applications

Google Earth Engine Applications PDF

Author: Lalit Kumar

Publisher: MDPI

Published: 2019-04-23

Total Pages: 420

ISBN-13: 3038978841

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In a rapidly changing world, there is an ever-increasing need to monitor the Earth’s resources and manage it sustainably for future generations. Earth observation from satellites is critical to provide information required for informed and timely decision making in this regard. Satellite-based earth observation has advanced rapidly over the last 50 years, and there is a plethora of satellite sensors imaging the Earth at finer spatial and spectral resolutions as well as high temporal resolutions. The amount of data available for any single location on the Earth is now at the petabyte-scale. An ever-increasing capacity and computing power is needed to handle such large datasets. The Google Earth Engine (GEE) is a cloud-based computing platform that was established by Google to support such data processing. This facility allows for the storage, processing and analysis of spatial data using centralized high-power computing resources, allowing scientists, researchers, hobbyists and anyone else interested in such fields to mine this data and understand the changes occurring on the Earth’s surface. This book presents research that applies the Google Earth Engine in mining, storing, retrieving and processing spatial data for a variety of applications that include vegetation monitoring, cropland mapping, ecosystem assessment, and gross primary productivity, among others. Datasets used range from coarse spatial resolution data, such as MODIS, to medium resolution datasets (Worldview -2), and the studies cover the entire globe at varying spatial and temporal scales.

Neutralising the Effects of Branch Mismatch Arrangements, Action 2

Neutralising the Effects of Branch Mismatch Arrangements, Action 2 PDF

Author: Organization for Economic Development and Cooperation

Publisher: Organization for Economic Co-Operation & Development

Published: 2017

Total Pages: 0

ISBN-13: 9789264277953

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This 2017 report sets out recommendations for branch mismatch rules that would bring the treatment of these structures into line with the treatment of hybrid mismatch arrangements as set out in the 2015 Report on Neutralising the Effects of Hybrids Mismatch Arrangements (Action 2 Report). Branch mismatches arise where the ordinary rules for allocating income and expenditure between the branch and head office result in a portion of the net income of the taxpayer escaping the charge to taxation in both the branch and residence jurisdiction. Unlike hybrid mismatches, which result from conflicts in the legal treatment of entities or instruments, branch mismatches are the result of differences in the way the branch and head office account for a payment made by or to the branch. The 2017 report identifies five basic types of branch mismatch arrangements that give rise to one of three types of mismatches: deduction / no inclusion (D/NI) outcomes, double deduction (DD) outcomes, and indirect deduction / no inclusion (indirect D/NI) outcomes. This report includes specific recommendations for improvements to domestic law intended to reduce the frequency of branch mismatches as well as targeted branch mismatch rules which adjust the tax consequences in either the residence or branch jurisdiction in order to neutralise the hybrid mismatch without disturbing any of the other tax, commercial or regulatory outcomes. The annexes of the report summarise the recommendations and set out a number of examples illustrating the intended operation of the recommended rules.

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