The Resource Federal income taxation of space and ocean activities

Federal income taxation of space and ocean activities

Label
Federal income taxation of space and ocean activities
Title
Federal income taxation of space and ocean activities
Creator
Subject
Summary
After a brief survey of the treatment of space and ocean activities under prior law, this article summarizes the relevant provisions of the 1986 Code. It gives special emphasis to the interplay among the new sourcing rules, the Subpart F rules, and the foreign tax credit limitation. It criticizes the new provisions and analyses a number of hypothetical transactions. Concluding the look-through treatment for space and ocean income earned by U.S.-controlled foreign corporations should be considered. If instead the Subpart F approach is retained for space and ocean income, it should be extended to cover international communications income earned by CFCs
Citation source
In: International tax journal. - Greenvale NY. - Vol. 14 (1988),
http://library.link/vocab/creatorName
Kelly, C. (Christopher)
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • continental shelf
  • space and ocean activities, income from
  • CFC
  • federal income tax
Label
Federal income taxation of space and ocean activities
Instantiates
Publication
Label
Federal income taxation of space and ocean activities
Publication

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      52.3736660 4.9336932
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