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  • 26 U. S. Code § 954 - Foreign base company income
    Prior to amendment, par (4), exception for foreign corporations not availed of to reduce taxes, read as follows: “For purposes of subsection (a), foreign base company income does not include any item of income received by a controlled foreign corporation if it is established to the satisfaction of the Secretary that neither—
  • 26 CFR 1. 954-4 -- Foreign base company services income.
    A controlled foreign corporation's distributive share of a partnership's services income will be deemed to be derived from services performed for or on behalf of a related person, within the meaning of section 954(e)(1)(A), if the partnership is a related person with respect to the controlled foreign corporation, under section 954(d)(3), and
  • LB I International Practice Service Concept Unit - Internal Revenue Service
    IRC 954(e)(2) (flush language) This last statement applies to taxable years of a foreign corporation beginning after December 31, 1998, and before January 1, 2015, unless it is extended by Congress
  • IRC Sec. 954 (Foreign base company income) | Tax Notes - Tax Analysts
    IRC section 954 defines foreign base company income (FBCI) to include foreign personal holding company income (FPHCI), foreign base company sales income (FBCSI), and foreign base company services income (FBCSvI) An exception is made for high-tax income FPHCI includes dividends, interest, royalties, and rents
  • 26 CFR § 1. 954-4 - Foreign base company services income.
    (a) Assistance furnished by a related person or persons to the controlled foreign corporation shall include, but shall not be limited to, direction, supervision, services, know-how, financial assistance (other than contributions to capital), and equipment, material, or supplies
  • PART 4—TEMPORARY INCOME TAX REGULATIONS UNDER SECTION 954 OF THE . . .
    Adjusted net foreign base company income (or adjusted net insurance income) equals the net foreign base company income (or net insurance income) of a controlled foreign corporation, reduced by any item of such income (other than foreign base company oil related income as defined in section 954(g)) subject to the high tax exception provided by
  • MIDV-954 [Uncensored Leaked] Dream Woman Vol. 99 Nana Yagi (Blu-ray Disc)
    MIDV-954 Dream Woman Vol 99 Nana Yagi (Blu-ray Disc) Uncensored Leaked 12705 02:00:00 MIDV-269 [Uncensored Leaked] “Teacher, I Will Become A Teacher ” Dense Sexual Intercourse Uncensored Leaked 3516 02:30:00 MIDV-394 [Uncensored Leaked] Gemstone You Are Sure To Be An Angel With A Fluffy Smile And
  • eCFR :: 26 CFR Part 1 - Controlled Foreign Corporations
    § 1 954-4: Foreign base company services income § 1 954-5: Increase in qualified investments in less developed countries; taxable years of controlled foreign corporations beginning before January 1, 1976 § 1 954-6: Foreign base company shipping income § 1 954-7: Increase in qualified investments in foreign base company shipping
  • Solve 954div4 | Microsoft Math Solver
    Reduce the fraction \frac{954}{4} to lowest terms by extracting and canceling out 2
  • Changes to Subpart F Services “Substantial Assistance” Test
    In defining FBCSI, Regs Sec 1 954-4(b)(1)(iv) provides that “services which are performed for, or on behalf of, a related person” include “substantial assistance” furnished by a related person to the CFC This assistance is generally determined through either the subjective or the objective test





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