The added burden of federal income taxation
would divert some degree of management attention to address tax issues," he said.
High court case summaries; federal income taxation
, keyed to Freeland, Lathrope, Lind, and Stephens' Casebook on federal income taxation
, 13th edition.
An alien becomes a resident alien by holding a green card and will be subject to Federal income taxation
on worldwide income from the first day of physical presence in the U.
Taxation of property transactions is emphasized because federal income taxation
is a prerequisite to other tax courses.
Christopher Hoyt is a law professor at the University of Missouri - Kansas City where he teaches classes on federal income taxation
and business organizations.
This is important, because an interest payment from a German CFC to an affiliated Dutch CFC would generally give rise to subpart F income (and, thus, current Federal income taxation
of the interest), thereby reducing or eliminating the benefit.
And partner David Miller, resident in New York, with associate Shlomo Boehm, penned the chapter "The US Federal Income Taxation
Treatment of Insurance-Linked Securities," providing insight on corporate, withholding, and excise taxes, as well as the federal income tax treatment of investors in catastrophe bonds.
Alter, an attorney in the Washington DC Tax Department, focuses his practice on federal income taxation
, with particular emphasis on the structuring and negotiation of taxable and tax-free corporate acquisitions, reorganizations, spinoffs and dispositions of ongoing business enterprises, the development of partnership and other joint-venture arrangements and tax planning for financings and other capital formation transactions.
The Taxes & Investing pamphlet summarizes the basic rules governing the federal income taxation
of certain investments by individuals who are citizens or residents of the United States and who dispose of an investment in a taxable transaction.
The example indicates that the taxpayer demonstrated reasonable cause and good faith by seeking advice from the professional, unless he "sought advice from someone that he knew, or should have known, lacked knowledge in federal income taxation
federal income taxation
at rates applicable to long-term capital gains, which currently are taxed at a maximum of 15%.
violates the condition that assets are subject to claims of general creditors), the employee might be subject to Federal income taxation
in the year the contributions are made, even if fund distributions are not received until many years later, pursuant to the economic benefit doctrine or Secs.
1993); Tax Court Litigation, BNA Tax Management Portfolio #630; "Tax Court Jurisdiction, Procedure and Practice," Mertens Law of Federal Income Taxation
, Chapter 50.
The trust fund will be treated as a qualified REIT subsidiary, however, and accordingly will not be subject to federal income taxation
as a corporation, as long as 100% of the equity securities are owned by a single REIT.
If COD income escapes Federal income taxation
through one of these exceptions, the debtor reduces carryforward tax attributes, such as net operating losses (NOLs), credit carryforwards and the adjusted bases of assets owned by the debtor.