income splitting definition

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714 documents for income splitting definition
  • The federal income tax system treats married couples as if each spouse earned approximately one-half of the couple's combined income through a mechanism called "income splitting." For many one-earner and unequal-earner couples, income splitting produces a significant advantage, a "marriage bonus," by shifting income from higher to lower rate brackets. Marriage-based income splitting relies on a presumption that marriage is a good indicator of economic unity between two taxpayers. It is not. Marriage does not require spousal sharing, and many unmarried couples share everything they earn. As a result, the current system extends the benefit of income splitting to some taxpayers who do not deserve it while withholding it from others who do. Because marriage is a poor proxy for economic unit...

    ... incompatible with an accessions-based definition of income 105 because it effectively treats gifts...

  • ... a "matching rule" to prevent the splitting of foreign tax credits from associated foreign inc... acquisition transactions where the foreign income is not subject to U.S. tax; and . * Amendment of S... significant ambiguity around the definition of a "splitting event" as well as the definition o...

  • This document contains final and temporary Income Tax Regulations with respect to a new provision of the Internal Revenue Code (Code) that addresses situations in which foreign income taxes have been separated from the related income. These regulations are necessary to provide guidance on applying the new statutory provision, which was enacted as part of legislation commonly referred to as the Education Jobs and Medicaid Assistance Act (EJMAA) on August 10, 2010. These regulations affect taxpayers claiming foreign tax credits. The text of the temporary regulations also serves as the text of the proposed regulations (REG-132736-11) published in the Proposed Rules section of this issue of the Federal Register.

    ...B. Definitions and Special Rules. Section 1.909-1T(a) provide...

  • ... denies only nonresident taxpayers a state income tax deduction for alimony paid. Petitioners-a Conn... by the State's adoption of an "income splitting" regime that creates parity in the tax treatment o... question of form, construction, or definition, but upon the practical operation and effect of th...

  • ...The Current Income Tax Treatment of Pregnancy-Related Transfers 1. A ... that any attempt at a generalized definition of the institution is meaningless, (66) she emphas... extends to former spouses the income-splitting benefits to which they were entitled during marria...

  • ... 909, the foreign tax credit anti-splitting rule, applies to foreign taxes paid or accrued in ... otherwise deemed paid--until the related income is taken into account for U.S. tax purposes). . Se.... . relating to the definition of a foreign tax credit splitting event will apply...

  • This document contains final Income Tax Regulations which provide guidance relating to the determination of who is considered to pay a foreign income tax for purposes of the foreign tax credit. These regulations provide rules for identifying the person with legal liability to pay the foreign income tax in certain circumstances. These regulations affect taxpayers claiming foreign tax credits.

    ... that there is a foreign tax credit splitting event if a foreign income tax is paid or accrued b...

  • ... inconsistent reports regarding the Coles' income. Incongruously, although Scott engineered much of ... the Internal Revenue Code's broad definition of "gross income." In Comm'r v. Glenshaw Glass Co.... Bentley revenues to Scott rather than splitting them equally with Darren as the partnership agreem...

  • ... surgery' that is excluded from the definition of 'medical care' by sec. 213(d)(9)(A), I.R.C., an... of $5,679 in petitioner's Federal income tax for 2001. After concessions, 1 the issue for d... this disallowance in such a way that splitting hairs in order to find a procedure not to be withi...

  • ... the elimination of the tax deferral on income earned through a partnership by a corporation, an ... families, measures to eliminate income splitting arising from capital gains, and measures to expand...Budget 2011 proposes to expand the definition of QET to include trusts created after 2011 in con...



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