Avoiding U.S.-source income can be difficult: the Tax Court reallocates franchise sale

Article Abstract:

The Tax Court did not accept the taxpayer-seller's foreign-source characterization of its income resulting from a franchise sale of foreign situs franchises for purposes of the IRC section 904(a) foreign tax credit in its Mister Donut decision. The court referred to section 865 sourcing rules to reallocate items of income as US source. The court held that intangibles such as goodwill were inherent in the franchise interest which it had determined to produce US source income.

Franchises, Foreign source income taxation

---

The reform of the Italian tax system

Article Abstract:

The Italian government in 1997 enacted several provisions which reformed the tax system. The changes made impact individuals and corporations and include substantive and procedural provisions. Substantive provisions include those relating to tax rates, dual taxation, regional taxation, corporate reorganizations, and value-added tax. Procedural issues addressed include negotiation and ruling procedures.

Italy, Tax Law, Analysis, Tax reform

---

Harbor maintenance tax on exports avoided

Article Abstract:

The US Federal Circuit Court of Appeals properly affirmed the US Court of International Trade's holding that the US harbor maintenance tax was unconstitutional in U.S. Shoe Corp. v. United States. The tax which is levied on cargo was held to be void as applied to exports in violation of the Export Clause.

Excise Taxes, Marine cargo handling, Ports, Management, Constitutional law, Constitutional interpretation, Harbors, Maintenance, Export duties

Similar abstracts:

• Abstracts: End of the road for the Taliban? An opportunist returns: Afghanistan. The battle for Afghanistan
• Abstracts: How smart women handle liquor. Be a smart drinker. Are you truly, madly, deeply charming?
• Abstracts: Hungry mouths to feed. Octopus reaches for sex guide
• Abstracts: Minimise the tax burden from a private company sale. Exit strategy
• Abstracts: 'He thinks he can fix anything.' 'He thinks he's a master chef.'. 'My husband has gotten too close to her'

This website is not affiliated with document authors or copyright owners. This page is provided for informational purposes only. Unintentional errors are possible.