The Operation And Effect Of The International Boycott Provisions Of The Internal Revenue Code PDF Download

Excerpt from The Operation and Effect of the International Boycott Provisions of the Internal Revenue Code: Third Report The Tax Reform Act of 1976 added several provisions to the Internal Revenue Code denying certain tax benefits to taxpayers who participate in or cooperate with an inter national boycott. The tax benefits affected by the boycott provisions are (1) the foreign tax credit, (2) the deferral of tax on the earnings of foreign subsidiaries, and (3) the deferral of tax on the earnings of Domestic International Sales Corporations. According to the General Explanation of the Tax Reform Act of 1976 Congress believes that these three tax not be made available with respect to operations in connection with which there has been an agreement to participate in or cooperate with an international boycott. The international boycott provisions allow a choice between two methods for computing the amount of tax benefits lost. The specifically attributable income and taxes method and the international boycott factor method. Under the specifically attributable income and taxes method, the benefits of the foreign tax credit are denied by reducing the amount of taxes eligible for the credit. Under the international boycott factor method, the benefits: of the foreign tax credit are denied by reducing the otherwise allowable credit. The benefits of disc and deferral are denied under both methods of computation by requiring a deemed distribution of earnings to the shareholders of the disc or controlled foreign corporation. The international boycott provisions are described in Chapter 2. About the Publisher Forgotten Books publishes hundreds of thousands of rare and classic books. Find more at www.forgottenbooks.com This book is a reproduction of an important historical work. Forgotten Books uses state-of-the-art technology to digitally reconstruct the work, preserving the original format whilst repairing imperfections present in the aged copy. In rare cases, an imperfection in the original, such as a blemish or missing page, may be replicated in our edition. We do, however, repair the vast majority of imperfections successfully; any imperfections that remain are intentionally left to preserve the state of such historical works.