Intercompany transaction definition8/23/2023 ![]() The taxpayer must adjust gross income attributable to the payer foreign branch downward (but not below zero) to reflect the allocable amount of the disregarded payment. section 1.904-4(f)(2)(vi)(A) applies when a foreign branch makes a disregarded payment to its owner, or a second foreign branch, and the disregarded payment is allocable to gross income that would be attributable to the foreign branch under the rules in reg. section 1.904-4(f)(2)(vi)(G) that govern the adjustments to gross income under paragraph (A) and allocation of disregarded payments under paragraph (B) when non-branch taxable units are present. This article focuses on the rules in reg. ![]() the treatment of disregarded payments made or received by non-branch taxable units.the treatment of multiple disregarded payments made in one tax year and. ![]() ![]()
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