§922
477 cases·126 followed·15 distinguished·6 questioned·86 overruled·244 cited—26% support
Statute Text — 26 U.S.C. §922
Statute text not available for this section.
477 Citing Cases
UCFSC elected to be taxed as an FSC pursuant to section 922(a)(2) on March 13, 1985.
922(a), 111 Stat. 879- 880. Section 1402(k) exempts insurance salesman termination payments from self-employment tax if, among other things, the amount of the payments “does not depend to any extent on length of service or overall earnings from services performed for such company (without regard to whether eligibility for payment depends on le
UCFSC elected to be taxed as an FSC pursuant to section 922(a)(2) on March 13, 1985.
Effective Tax Rate Cut for Qualifying Income Ifa corporation qualified as an FSC under section 922, its "exempt foreign trade income" (EFTI) was not taxed by the United States (more precisely, EFTI was treated as foreign source income which was not effectively connected with the conduct ofa trade or business within the United States).
Effective Tax Rate Cut for Qualifying Income Ifa corporation qualified as an FSC under section 922, its "exempt foreign trade income" (EFTI) was not taxed by the United States (more precisely, EFTI was treated as foreign source income which was not effectively connected with the conduct ofa trade or business within the United States).
corporation was entitled to claim the deduction then allowed by section 922 to Western Hemisphere trade corporations.
1954. The WHTC provisions, I.R.C. 1954 secs. 921 and 922, were repealed by sec. 1052(b) of the Tax Reform Act of 1976, Pub. L. 94-455, 90 Stat. 1520, 1648. Several opinions of this and other courts have noted the general similarity of congressional purpose between the possessions corporations provisions and the WHTC provisions. In
1954. The WHTC provisions, I.R.C. 1954 secs. 921 and 922, were repealed by sec. 1052(b) of the Tax Reform Act of 1976, Pub. L. 94-455, 90 Stat. 1520, 1648. Several opinions of this and other courts have noted the general similarity of congressional purpose between the possessions corporations provisions and the WHTC provisions. In
1954. The WHTC provisions, secs. 921 and 922, I.R.C. 1954, were repealed by section 1052(b) of the Tax Reform Act of 1976, Pub. L. 94-455, 90 Stat. 1520, 1648. Several opinions of this and other courts have noted the general similarity of congressional purpose between the possessions corporations provisions and the WHTC provisions.