This condition is intended to limit foreign use to situations in which the foreign income that would be offset by the DCL is not currently
subject to U.
A person
subject to the jurisdiction of the United States covers any person who is a citizen, permanent resident alien or, in some cases, a resident of the United States.
that are
subject to Title VI stratospheric ozone protection requirements;
Thus, an employee's right to deferred amounts is generally
subject to a substantial risk of forfeiture for as long as the employee is required to perform additional services to be entitled to payment of the amounts (i.
These forward-looking statements are based on assumptions that are
subject to significant known and unknown risks, uncertainties and other unpredictable factors, many of which are described in Zion's prospectus and are beyond Zion's control.
The IRS has attempted to mitigate this advantage by arguing that distributions paid to S shareholders, in lieu of paying a reasonable salary, constitute wages
subject to employment taxes; see Rev.
The court concluded that some of the payments were not wages
subject to FICA or RRTA.
902 (1971), the court decided that the corporation was
subject to tax based on the presence of detail people and their leased automobiles in the State.
However, single-owner LLCs that are not taxed as a corporation are
subject to employment tax liabilities.
Specifically, the following types of M&E expenses a taxpayer incurs are not
subject to the 50% tax ceiling:
In addition, the Court held that International Shoe was
subject to the jurisdiction of the Washington courts.
shareholders of foreign corporations can be
subject to tax under the CFC and PFIC anti-deferral provisions; the FPHC provisions have been repealed.
