§841 — Credit for foreign taxes
205 cases·33 followed·4 questioned·24 overruled·144 cited—16% support
Statute Text — 26 U.S.C. §841
The taxes imposed by foreign countries or possessions of the United States shall be allowed as a credit against the tax of a domestic insurance company subject to the tax imposed by section 801 or 831, to the extent provided in the case of a domestic corporation in section 901 (relating to foreign tax credit). For purposes of the preceding sentence (and for purposes of applying section 906 with respect to a foreign corporation subject to tax under this subchapter), the term “taxable income” as used in section 904 means—
in the case of the tax imposed by section 801, the life insurance company taxable income (as defined in section 801(b)), and
in the case of the tax imposed by section 831, the taxable income (as defined in section 832(a)).
205 Citing Cases
§§ 841(a)(1), 841(c)(2), 846, 856(a)(1), and 18 U.S.C. §§ 2, 1956(h), and 1957. Before his criminal conviction, petitioner was a pharmacist in Kentucky. The indictments included allegations with respect to petitioner’s assets, including a T. Rowe Price Associates, Inc. employee IRA (T. Rowe Price IRA). In 2017, following a jury trial, petitioner was
Further, the Federal statute criminalizing - 22 - trafficking in counterfeit goods or services provides that "the term 'traffic' means to transport, transfer, or otherwise dispose of, to another, for purposes of commercial advantage or private financial gain, or to make, import, export, obtain control of, or possess, with intent to so transport, transfer, or otherwise dispose of".
Further, the Federal statute criminalizing - 22 - trafficking in counterfeit goods or services provides that "the term 'traffic' means to transport, transfer, or otherwise dispose of, to another, for purposes of commercial advantage or private financial gain, or to make, import, export, obtain control of, or possess, with intent to so transport, transfer, or otherwise dispose of".
Further, the Federal statute criminalizing - 22 - trafficking in counterfeit goods or services provides that "the term 'traffic' means to transport, transfer, or otherwise dispose of, to another, for purposes of commercial advantage or private financial gain, or to make, import, export, obtain control of, or possess, with intent to so transport, transfer, or otherwise dispose of".
Further, the Federal statute criminalizing - 22 - trafficking in counterfeit goods or services provides that "the term 'traffic' means to transport, transfer, or otherwise dispose of, to another, for purposes of commercial advantage or private financial gain, or to make, import, export, obtain control of, or possess, with intent to so transport, transfer, or otherwise dispose of".
Further, the Federal statute criminalizing - 22 - trafficking in counterfeit goods or services provides that "the term 'traffic' means to transport, transfer, or otherwise dispose of, to another, for purposes of commercial advantage or private financial gain, or to make, import, export, obtain control of, or possess, with intent to so transport, transfer, or otherwise dispose of".
Further, the Federal statute criminalizing - 22 - trafficking in counterfeit goods or services provides that "the term 'traffic' means to transport, transfer, or otherwise dispose of, to another, for purposes of commercial advantage or private financial gain, or to make, import, export, obtain control of, or possess, with intent to so transport, transfer, or otherwise dispose of".
841(a) (1) and (b) (1) (A); (ii) money laundering in violation of 18 U.S.C. Sec. 1956 (a) (3) (A) , (B) , and (C) ; and (iii) attempting to possess cocaine with .intent to distribute in violation of 21 U.S.C. sec. 846. . Plea Agreement, United States v. Penland, No. 7:05-cr-00710-HFF (Mar. 14, 2006), ECF No. 234. Charles Penland agreed to forf
section 841(a)(1) and (b)(1)(A) by possessing cocaine with the intent to distribute during the period January 1993 through at least September 2, 1998, and (2) 26 U.S.C. section 7206(1) by filing a false and fraudulent tax return for each of the taxable years 1994, 1995, 1996, and 1997. On February 28, 2000, Mr. Clinkscale entered into a plea agreem
A person commits theft through a false promise when: with the intent prescribed in § 841 of this title, the person obtains property of another person by means of a representation, express or implied, that the person * * * will in the future engage in particular conduct, and * * * the person does not intend to engage in such conduct