Foreign Investment Incentive Act: Hearings Before the Committee on Ways and Means, House of Representatives, Eighty-sixth Congress, First Session, on H. R. 5, a Bill to Amend the Internal Revenue Code of 1954 to Encourage Private Investment Abroad and Thereby Promote American Industry and Reduce Government Expenditures for Foreign Economic Assistance. July 7,8, and 9, 1959U.S. Government Printing Office, 1959 - 616 páginas Considers H.R. 5, the Foreign Investment Incentive Tax Act of 1959, to provide tax incentives to encourage capital investment and trade expansion with developing countries, especially by small businesses. |
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Términos y frases comunes
amendment American business assets base companies believe benefit Boggs bill Brazil capital CHAIRMAN committee competition Corp CURTIS developed countries DILLON dividends dollars domestic corporation earnings effect enactment encourage enterprise export income foreign business corporation foreign corporation foreign countries foreign income foreign investment foreign operations foreign source income foreign subsidiaries foreign tax credit foreign trade free world funds Hale Boggs Hemisphere trade corporation holding company important income tax increase industry Internal Revenue Code investment abroad investors KEARNS Latin America legislation limitation LINDSAY MACHROWICZ manufacturing markets ment million nations operating abroad overseas percent permit present private investment problem profits proposed question reinvested revenue loss RUSSELL BAKER Sears section 367 SIMPSON statement substantial tax deferral tax haven tax incentives tax laws tax rate tax sparing tax treaties taxable taxation taxpayer tion Treasury Department U.S. corporation U.S. foreign business U.S. tax underdeveloped countries United vice president Western Hemisphere trade
Pasajes populares
Página 3 - Except as otherwise expressly provided, whenever in this Act an amendment or repeal is expressed in terms of an amendment to, or repeal of, a section or other provision, the reference shall be considered to be made to a section or other provision of the Internal Revenue Code of 1954.
Página 6 - ... a corporation unless, before such exchange, it has been established to the satisfaction of the Secretary or his delegate that such exchange is not in pursuance of a plan having as one of its principal purposes the avoidance of Federal income taxes. For purposes of this section, any distribution described in section 355 (or so much of section 356 as relates to section 355) shall be treated as an exchange whether or not it is an exchange.
Página 6 - Act of 1932; or (b) if prior to the transfer it has been established to the satisfaction of the Commissioner that such transfer is not in pursuance of a plan having as one of its principal purposes the avoidance of Federal income taxes.
Página 55 - A statement setting forth the various classes of stock outstanding, the name and address of each shareholder, the class and number of shares held by each on the date of payment of the dividend with respect to which the claim...
Página 411 - In the case of a domestic corporation engaged in business in a foreign country, its assets and liabilities (other than capital assets) recorded on its books in terms of the foreign currency, should be appraised in dollars (whether actually converted or not) at the close of each taxable year in which it is engaged in active business at the current or market rate of exchange, if any, then prevailing. (But see ARB 15, 3-20-682.)" (Italics supplied.) Under this version of the balance sheet method, all...
Página 4 - In the case of a foreign corporation the deductions shall be allowed only if and to the extent that they are connected with income from sources within the United States ; and the proper apportionment and allocation of the deductions with respect to sources within and without the United States shall be determined as provided in section 119, under rules and regulations prescribed by the Commissioner with the approval of the Secretary. (b) CHARITABLE, AND so FORTH, CONTRIBUTIONS. — The so-called "charitable...
Página 8 - For purposes of this subpart and of sections 164(a) and 275 (a), the term "income, war profits, and excess profits taxes shall include a tax paid in lieu of a tax on income, war profits, or excess profits otherwise generally imposed by any foreign country or by any possession of the United States.
Página 614 - Two or more issuers are not considered as being in the same or similar trades or businesses merely because they are engaged in the broad field of manufacturing or of any other general classification of industry, but issuers shall be construed to be engaged in the same or similar trades or businesses if they are engaged in a distinct branch of business, trade, or manufacture in which they render the same kind of service or produce or deal in the same kind of product, and such service or products fulfill...
Página 6 - ... parent corporation owns, directly or indirectly, more than 50 percent of the outstanding voting stock of such other corporation, and (B) Such other corporation Is not a personal holding company for the taxable year in which the dividends are paid. (c) Exceptions. The term "personal holdIng company" as defined in subsection (a) does not Include — (1) A corporation exempt from tax under subchapter F (sec.
Página 5 - Code, and the regulations thereunder, or under the provisions of an applicable tax convention, shall not be included in the gross income of a nonresident alien individual.