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
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.
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tax under the CFC and PFIC anti-deferral provisions; the FPHC provisions have been repealed.