Tax Court attributes contract manufacturer's activities to principal
Article Abstract:
The authors discuss the US Tax Court's decision in Suzy's Zoo in regard to the use of contract manufacturers and the generation of foreign income.
Publication Name: Taxes: The Tax Magazine
Subject: Business
ISSN: 0040-0181
Year: 2000
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Final code sec. 894 regulations: treaty benefits for hybrid entity payments
Article Abstract:
The authors discuss the IRS' final regulations regarding tax treaty benefits for hybrid corporate entities under IRC section 894.
Publication Name: Taxes: The Tax Magazine
Subject: Business
ISSN: 0040-0181
Year: 2000
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MedChem (P.R.) Inc.: the confused state of contract manufacturing
Article Abstract:
The authors discuss the US Tax Court's decision in MedChem (P.R.), Inc., in which the court failed to rule on whether contract manufacturing met the 'manufacturing exception' of IRC section 954(d)(1)(A).
Publication Name: Taxes: The Tax Magazine
Subject: Business
ISSN: 0040-0181
Year: 2001
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- Abstracts: New proposed code sec. 367(b) regulations govern the carryout of tax attributes in reorganizations involving foreign corporations
- Abstracts: A sequence-oriented comparison of gene expression measurements across different hybridization-based technologies
- Abstracts: Rev. proc. 2001-43 and the transfer of a nonvested partnership profits interest. Does code section 2704(b) apply in valuing a limited partnership interest