Add to ORKGIt is the design of this comment to delve into the history, scope and purpose of section 911 of the Internal Revenue Code and,in particular, of subsection 911(c)(3). This inquiry will be made in conjunction with a critical analysis of the Tax Court\u27s decision in Robert R. Bottome, a decision which results in unequal treatment of taxpayers in domiciled in community property states and non-community property states
United States Tax Principles Govern Determination of Accumulated Profits Under Foreign Tax Credit Se...
The author discusses the impact of recent Supreme Court decisions and congressional statutes on the ...
The purpose of this comment is to discuss the relatively short history of Internal Revenue Code § 28...
For a period of over twenty years the eight community property states have enjoyed the privilege of ...
This Note will examine the United States tax treatment of foreign source income, under sections 911 ...
This Comment analyzes two tax court decisions, Peterson v. Commissioner and Hokanson v. Commissioner...
Under Section 811 (e)(2), (g)(4) of the Internal Revenue Code, as amended by sections 402 and 404 of...
The United States taxes all income earned by a taxpayer, regardless of its source. To prevent double...
Foreign taxpayers have long been a thorn in the side of Congress. Not only is the proper incidence o...
The bipartisan tax reform bill recently introduced by Sens. Ron Wyden, D-Ore., and Judd Gregg, R-N.H...
For the first time since 1913, Congress is considering abandoning the principle that US residents sh...
In the years 1942-1948, the community property system wusadopted by state legislatures in Oregon, Ne...
The Commissioner of Internal Revenue issued jeopardy assessments against the taxpayer, Omar, S.A., a...
In McGlotten v. Connally, a three-judge federal court held that theSecretary of the Treasury could n...
The United States, for over three-quarters of a century, has maintained a foreign trade ...
United States Tax Principles Govern Determination of Accumulated Profits Under Foreign Tax Credit Se...
The author discusses the impact of recent Supreme Court decisions and congressional statutes on the ...
The purpose of this comment is to discuss the relatively short history of Internal Revenue Code § 28...
For a period of over twenty years the eight community property states have enjoyed the privilege of ...
This Note will examine the United States tax treatment of foreign source income, under sections 911 ...
This Comment analyzes two tax court decisions, Peterson v. Commissioner and Hokanson v. Commissioner...
Under Section 811 (e)(2), (g)(4) of the Internal Revenue Code, as amended by sections 402 and 404 of...
The United States taxes all income earned by a taxpayer, regardless of its source. To prevent double...
Foreign taxpayers have long been a thorn in the side of Congress. Not only is the proper incidence o...
The bipartisan tax reform bill recently introduced by Sens. Ron Wyden, D-Ore., and Judd Gregg, R-N.H...
For the first time since 1913, Congress is considering abandoning the principle that US residents sh...
In the years 1942-1948, the community property system wusadopted by state legislatures in Oregon, Ne...
The Commissioner of Internal Revenue issued jeopardy assessments against the taxpayer, Omar, S.A., a...
In McGlotten v. Connally, a three-judge federal court held that theSecretary of the Treasury could n...
The United States, for over three-quarters of a century, has maintained a foreign trade ...
United States Tax Principles Govern Determination of Accumulated Profits Under Foreign Tax Credit Se...
The author discusses the impact of recent Supreme Court decisions and congressional statutes on the ...
The purpose of this comment is to discuss the relatively short history of Internal Revenue Code § 28...