This so-called economic substance doctrine has been used by the federal courts for a half-century to strike down complex and creative instances of self-dealing - such as intracompany stock transfers intended to generate tax-reducing losses - that have no business purpose beyond avoiding the taxman. ❋ Unknown (2010)
HyperIP for Cloud, which is designed for cloud-to-customer transfers instead of intracompany transfers, ships as a VMware appliance and is sold through resellers, including managed service providers and storage companies with cloud backup and disaster recovery offerings. ❋ Unknown (2009)
At the time of the restructuring, Aurelius said the company was in breach of its credit agreements, alleging that Energy Future was paying too little on intracompany loans from Texas Competitive Electric. ❋ Katy Burne (2011)
Focusing on deficits and surpluses ignores equally important flows of capital, as well as the phenomenon of supply chains and the intracompany trade that crosses borders. ❋ Unknown (2010)
If you want to avoid a big outlay of cash, Seidel advises making one of two types of switches: intracompany moves or gradual transitions. ❋ Laura Sinberg (2010)
Financial statements the world over back-out intracompany transactions, and for good reason, because there is an offsetting asset that cancels out the debt directly. ❋ Unknown (2009)
Currently, many Chinese conglomerates conduct intracompany trade using U.S. dollars, which can be expensive and risky. ❋ Unknown (2009)
Ireland also has a corporate income tax but doesn't impose it on various intracompany transactions, thus making the tax relatively easy to avoid, say tax professionals. ❋ Unknown (2009)
NAFTA created four new non-immigrant visa classifications: the 30-day business visitor paid from a source outside of Mexico, the one-year professional in certain fields, the intracompany transferee having managerial, executive or specialized skills, and the investor/trader. ❋ Unknown (2006)
If this approach is carried to its logical conclusion, the multiregional producer will have an intracompany product portfolio and trade flow as shown in Figure 8.4, where the majority of demand is met by the production system within each region and cross-regional trade is reasonably balanced. ❋ James P. Womack (2007)
Tell those analysts that the alternative was a bloody intracompany war which would almost certainly destroy shareholder value in the 10 billion dollar range, and the decision becomes even easier. ❋ Unknown (2005)
I will note that adding interesting new functionality to Yahoo Mail is a good move, outside of any other intracompany strategy. ❋ Michael Arrington (2005)
It's called L-1, where they can, by intracompany transfers, bring in the same people and oust American workers. ❋ Unknown (2003)
In an intracompany trade, columnist Michael Smerconish - who has been published on Thursdays in the Daily News - will move to The Inquirer on Page A2 on Fridays. ❋ Unknown (2011)
A summary of the bill said the funds would be raised with a 2,000-dollar per visa increase in the price paid by specific companies for non-immigrant "H1B" visas for highly skilled workers or "L" visas for intracompany transfers. ❋ Unknown (2010)
