Guatemalan solidarity, extraordinary and temporary tax
Article Abstract:
Guatemala has enacted the Solidarity, Extraordinary and Temporary Tax (ISET) to impose a tax on both personal and corporate gross income in 1996 and 1997. The tax rate ranges from 1% to 3% of the prior year's income or net assets. Depending on the method used to calculate the ISET, the ISET may or may not be creditable for US foreign tax credit purposes. As currently constructed, the ISET is the primary levy and the Guatemalan income tax is the secondary levy under US multiple levy regulations. Guatemalan income tax laws should be revised for 1997 to acknowledge this.
Publication Name: Journal of Corporate Taxation
Subject: Law
ISSN: 0094-0593
Year: 1997
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Final section 6662 transfer pricing penalty rules
Article Abstract:
The author discusses IRS final regulations under IRC section 6662(e) which were issued Feb 8, 1996 and concern application of penalties for not maintaining transfer pricing documentation. The author discusses rules concerning transfer pricing methods, IRC section 482, and includes a list of documents which must be made available to the IRS upon request.
Publication Name: Journal of Corporate Taxation
Subject: Law
ISSN: 0094-0593
Year: 1997
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