References in periodicals archive ?
In Burke, the Supreme Court held that backpay awards, in settlement of a sex discrimination claim brought under Title VII prior to its amendment by the Civil Rights Act of 1991, are not excludable from gross income under section 104(a)(2).
Alternatively, the DASTM gain could be allocated based on the gross income (after the preceding DASTM allocations) within each category.
861-8 provides a two-step process in which these expenses are charged against gross income; first, expenses are allocated to the classes of gross income to which they are definitely related and, second, they are apportioned (within the class(es) of gross income) among statutory and residual groupings of gross income.
Our members have suggested, however, certain modifications to these regulations, including: (1) to permit the specific allocation of the entire transaction gain or loss with respect to certain liabilities to the "basket" from which it was generated; (2) to clarify the inclusion of DASTM currency gain or loss as part of gross income for purposes of gross income-based calculations; and (3) to clarify that section 988 assets and liabilities are translated at the year-end exchange rate in accordance with U.
Under IRC sections 61(a)(12) and 108(a), COD income is income; it simply is not included in gross income if a taxpayer is insolvent.
Under the bill, the PFIC 50-percent assets test would be retained for PFC purposes and the threshold 75-percent gross income test would be reduced to 60 percent.
Gross income for the corresponding period last year was $671,755 with net income of $504,628.
882 requirement that entitles a foreign corporation to take deduction against its gross income, but only if it timely files a U.
On his federal income tax return, the taxpayer deducted these state income taxes "above the line" on schedule E to arrive at his adjusted gross income.
source gross income or, alternatively, solely to foreign-source gross income.
Single person one child 2014/15 2015/16 Gross income 6,000 6,000 Tax allowances used 10,000 10,600 Car benefit 0 0 Taxable income 0 0 Gross tax 0 0 Married relief 0 0 NI contribution 0 0 Universal credit 7,990 8,067 Child benefit 1,066 1,076 Net income 15,056 15,144 Net change p/a GAIN 87 Weekly change 1.