Thus, the taxpayer could construct the building, derive
both rental income and depreciation and other tax deductions for a period of time, and then sell the building and include the gross receipts derived from the sale of the building in calculating a production deduction under section 199 for the year of sale.
Triangular rule: Like the treaties with South Africa and Switzerland, this rule imposes a 15% withholding tax when a resident of one CS derives
dividends, interest or royalties from the other CS, the income is attributable to a PE in a third jurisdiction, and the profits of that PE are subject to an aggregate effective tax rate in the CS of residence and the third jurisdiction that is less than 50% of the general rate of company tax applicable in the CS of residence (i.
Our goal is to derive
the highest possible value from discarded materials," she says.
863-9(f), Example 11 (provider of Internet access derives
communication income; replication of sites to speed up response considered de minimis).
Professional-The professional group includes end users or facilities that derive
primary income directly from using a DCC software application, such as a professional animator, post-production facility or audio recording studio.