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Ds that the activities of a contract manufacturer cannot be attributed to a controlled foreign corporation for purposes of either section 954(d)(1) or section 954(d)(2) of the Code to determine whether the income of a controlled foreign corporation is foreign base company sales income. The ruling, however, provides 7805(b) relief for taxable years of a controlled foreign corporation beginning before December 8, 1997. Rev. Rul. 97 48 In Rev. Rul. 75 7, 1975 1 C.B. 244, a controlled foreign.
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Incorporation FAQ
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A revenue ruling is an official interpretation by the IRS of the Internal Revenue Code, related statutes, tax treaties and regulations. It is the conclusion of the IRS on how the law is applied to a specific set of facts.
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Revenue Ruling 77-318 holds that a taxpayer may not exclude under § 104(a)(4) civil service disability payments for a retirement occasioned by injuries resulting from active military service. Rev. Rul. 77-318, 1977-2 C.B. 45.
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75-457 holds that the substitution of obligors, deeds of trust, and promissory notes, without any other changes, was not to be considered a satisfaction or disposition of an installment obligation under section 453(d) of the Code.
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Rul. 76-428 provide that a facility is “placed in service” when all the critical tests are successfully achieved and a “state of readiness and availability for a specifically assigned function”, such as “daily operation”, has been demonstrated even though subsequent testing may be performed to eliminate any defects.
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In Revenue Ruling 75-22, 1975 - 1 C.B. 49, the Internal Revenue Service considers the question of whether the portion of a retired minister's pension designated as a rental allowance by the national governing body of a religious denomination having complete control over the denomination's retirement fund may be ...
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Revenue Ruling 75-370 specifically states that painting does not qualify as a capital activity that may be excluded from the income of a homeowners association as a contribution to capital. Painting is considered to be a non annual maintenance expense.
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A taxpayer engaged in the trade or business of selling motor vehicles is presumed to hold all such vehicles primarily for sale to customers in the ordinary course of the taxpayer's trade or business.
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A revenue ruling is an official interpretation by the IRS of the Internal Revenue Code, related statutes, tax treaties and regulations. It is the conclusion of the IRS on how the law is applied to a specific set of facts.
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