Nextel argued that the NLC deduction limitation effectively resulted in disparate treatment of taxpayers, based solely on the size of the business as determined by
taxable income.
According to section 987's legislative history, taxpayers should adjust
taxable income or loss to the extent the value of the local currency at the time of remittance differs from the value when the amount was earned or otherwise recorded in the QBU's capital.
In fiscal 2005, Resona Holding limited its DTA amount to a sum equal to its projected one-year
taxable income, the holding company said.
Finally, major donors may choose to give the full $100,000 per year and avoid an additional $100,000 of reportable
taxable income.
55-1(a), which states: "Except as otherwise provided by statute, regulations, or other published guidance issued by the Commissioner, all Internal Revenue Code provisions that apply in determining the regular
taxable income of a taxpayer also apply in determining the alternative minimum
taxable income of the taxpayer.
The court disagreed, stating that IRC section 703(a) merely described how a partnership calculates its
taxable income before dividing that amount among the partners.
If the lease falls within the safe harbors provided under the code section, the tenant will avoid
taxable income and the landlord will be deemed the owner of the improvements.
In other words, companies can reduce their
taxable income by up to $100,000 a year.
In light of criticisms of existing studies, additional research on the impact of tax rate changes on
taxable income is warranted, and a study that uses an alternative approach to measure the tax or net-of-tax rate elasticity may yield independent evidence on this important issue.
The couple failed to report more than $1 million in
taxable income.
The top corporate rate increases--from 34% to 35%--on
taxable income over $10 million.
Single status filers whose "provisional income" is over $34,000 may have to report up to 85 percent of their benefits as
taxable income.
