Proposed Revision of I.R.C. 1563(a)(2): A New Definition for Brother-Sister Controlled GroupsA large corporation can reduce its taxes by dividing into several smaller corporations, since it thereby divides its income among the smaller corporations. The total income is thus taxed in lower ...
"Affiliate" means an entity that directly or indirectly controls, is under common control with, or is controlled by the business. Control exists in all cases in which the entity is a member of a controlled group of corporations as defined pursuant to section 1563 of the Internal Revenue Code...
controlled group of corporations, as defined in § 1563, is considered to be one corporation and all assets of all members of the group are aggregated. (2) A taxpayer with assets of less than $10 million at the end of its taxable year must comply with the record retention ...
Executive function and memory scores were derived from a principal component analysis of the test scores on five cognitive tests: Mental Alternation Test, Animal Fluency test, Controlled Oral Word Association Test, Stroop test, and Rey Auditory Verbal Learning Test with immediate and 5-minute recall...
Sample diagram of iterative simulation results of the leading vehicle and following vehicle1 (experimental vehicle group 1). (a)Velocity change relationship and (b) vehicle spacing changes. The driver-sensitivity coefficient 𝛼α was adjusted in this study to improve the model’s response to the...
1563(a)(2)(A)BROTHER-SISTER CONTROLLED CORPORATIONS: AN ANALYSIS OF THE CONFLICT OVERINTERPRETATION OF THE "80 For purposes of the application of the tax laws limiting certaintax Candidate for JD, May 1982, South Texas College of Law; Business ManagerSteinhoff, Judy A...