While defined as a "model act" the document is really a blueprint of the kinds of authorities
needed in an emergency.
In some cases, the Competent Authority process has not provided full relief from double taxation because the Competent Authorities
do not address issues involving deficiency interest or exchange gains and losses arising from the settlement.
For example, the Church authorities
say that artificial birth control is a serious sin.
If 40% of the factual evidence supports a taxpayer's reliance on legal authority, but 60% of the factual evidence supports the Service's claim that other authorities
control, the IRS will win the case but the substantial understatement will not apply.
While advocates fought in vain to capture the federal revenues generated by PCSP for IHSS program enhancements, they quickly began planning their next state policy initiatives and organizing support for Public Authorities
in counties throughout California.
operations were restricted largely to two types: selling gold to foreign authorities
for the dollars acquired by those authorities
in exchange market intervention; and, later, buying dollars from foreign authorities
in return for that country's currency, which the United States had acquired by drawings on the Federal Reserve swap network and the issuance of bonds denominated in foreign currencies.
No wonder, when we consider the mountains of outward authorities
through which we trudge in a lifetime, that few Catholics are wont to throw enthusiastic parties on the feast of Christ the King.
If a return position is reasonably based on one or more of the authorities
set forth in [sections] 1.
6661-3 specified that there is substantial authority for the tax treatment of an item only if the weight of authorities
supporting the taxpayer's position is substantial in relation to the weight of authorities
supporting contrary treatment of the item in question.
According to press reports, the IRS is considering modification of this provision because foreign competent authorities
sometimes balk at Appeals settlements on the ground they are based on the hazards of litigation rather than resolution of the legal or factual issues involved in the Competent Authority dispute.
For purposes of determining the amount of foreign tax creditable under sections 901 and 902 of the Internal Revenue Code, any amounts paid to foreign tax authorities
that would not have been due if the treaty country had made a correlative adjustment may not constitute a creditable foreign tax .
and foreign competent authorities
to obtain a bilateral agreement is highly desirable.