The Resource Four papers to be discussed during BIAC Tax Committee meeting of 17 April 1996: (1) Monitoring procedure of the 1995 OECD Report on Transfer Pricing: BIAC Statement on the IRS Final regulations concerning Accuracy-related Penalties under Section 6662(e) of the Internal Revenue Code (IRC); (2) Residence of a Company for Tax Purposes; (3) Dividend Streaming; (4) Tax Deductibility of Capital Expenditure

Four papers to be discussed during BIAC Tax Committee meeting of 17 April 1996: (1) Monitoring procedure of the 1995 OECD Report on Transfer Pricing: BIAC Statement on the IRS Final regulations concerning Accuracy-related Penalties under Section 6662(e) of the Internal Revenue Code (IRC); (2) Residence of a Company for Tax Purposes; (3) Dividend Streaming; (4) Tax Deductibility of Capital Expenditure

Label
Four papers to be discussed during BIAC Tax Committee meeting of 17 April 1996: (1) Monitoring procedure of the 1995 OECD Report on Transfer Pricing: BIAC Statement on the IRS Final regulations concerning Accuracy-related Penalties under Section 6662(e) of the Internal Revenue Code (IRC); (2) Residence of a Company for Tax Purposes; (3) Dividend Streaming; (4) Tax Deductibility of Capital Expenditure
Title
Four papers to be discussed during BIAC Tax Committee meeting of 17 April 1996: (1) Monitoring procedure of the 1995 OECD Report on Transfer Pricing: BIAC Statement on the IRS Final regulations concerning Accuracy-related Penalties under Section 6662(e) of the Internal Revenue Code (IRC); (2) Residence of a Company for Tax Purposes; (3) Dividend Streaming; (4) Tax Deductibility of Capital Expenditure
Creator
Subject
Summary
(1) Recommendations to OECD Working Party 6 to review the US regulations on transfer pricing penalties as part of the ongoing monitoring of the OECD's 1995 transfer pricing report. Includes summary of inconsistencies between the OECD and US rules, in particular as to the nature of the penalties, the method selection and data and documentation requirements; (2) Proposal to adopt a single (place of incorporation) test for company residence and to abolish tests based on management and control. The latter test is considered increasingly unsuitable to modern forms of doing business and susceptible of abuse by taxpayers; (3) Short position paper proposing the removal of legal obstacles to dividend streaming, i.e. dividends paid to foreign shareholders direct from foreign subsidiaries; (4) Short position paper arguing in favour of a deduction for all business expenditure whether capital or revenue. Illustratrative schedule of capital expenditure and related timing of deductions
http://library.link/vocab/creatorName
  • Gibbons, C
  • Werra, M
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • transfer pricing
  • residence
  • dividend
Label
Four papers to be discussed during BIAC Tax Committee meeting of 17 April 1996: (1) Monitoring procedure of the 1995 OECD Report on Transfer Pricing: BIAC Statement on the IRS Final regulations concerning Accuracy-related Penalties under Section 6662(e) of the Internal Revenue Code (IRC); (2) Residence of a Company for Tax Purposes; (3) Dividend Streaming; (4) Tax Deductibility of Capital Expenditure
Instantiates
Publication
Extent
20 p.
Label
Four papers to be discussed during BIAC Tax Committee meeting of 17 April 1996: (1) Monitoring procedure of the 1995 OECD Report on Transfer Pricing: BIAC Statement on the IRS Final regulations concerning Accuracy-related Penalties under Section 6662(e) of the Internal Revenue Code (IRC); (2) Residence of a Company for Tax Purposes; (3) Dividend Streaming; (4) Tax Deductibility of Capital Expenditure
Publication
Extent
20 p.

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