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861 |
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861
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| The section 861 regulations were tailored for the purpose of
allocating and apportioning income and expenses between foreign and
domestic sources under the foreign tax credit provisions of the Code. (Tokyo, Japan) has incorporated Silicon Image's
SiI 861 Digital Visual Interface (DVI)-compliant monitor controller into
its recently announced 5 and 7 Series Prius LCD PCs. 408, the IRS announced its intention
to modify the section 861 regulations essentially to eliminate the word
"generally," thereby requiring taxpayers to ratably apportion
the deduction for charitable contributions to all classes of gross
income on an affiliated group basis. |
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