methods and foreign tax credits; segregating activities that if combined in a single taxable entity, might be disadvantageous in fiscal terms; and taking advantage of favourable treatment for certain activities (e.g., anticipated or potential sales, mergers, liquidations or intrafamily gifts or [....
segregating activities that if combined in a singletaxableentity, might be disadvantageous in fiscal terms; and taking advantage of favourable treatment for certain activities (e.g., anticipated or potential sales, mergers, liquidations or intrafamily gifts or bequests) that is available for some ...
Generally, federal courts (and thus the IRS) abide by the terms of a settlement agreement if the terms are clear and the parties expressly assign the settlement payment or payments to one or more of the underlying claims or causes of action. However, if one or more of these requirements do...
[...]group members may be set off againstthetaxableincome of the other members of the group, donations between companieswill bedeemed to be a tax-deductible expense for the donor, the transfer pricing rules do not apply to transactions between group companies and only one companyinthegroup fil...