The possession tax credit under section 936 / by Ernest F. Aud, Murray Gordon, and David M. Benson.

Arlington, VA : Tax Management, [©2005]-

1 online resource.

Updated irregularly.

Tax management portfolios ; 933-2nd.

" ... discusses the provisions of [section] 936, which allows a credit to domestic corporations for certain business activities in Puerto Rico and the U.S. possessions. It examines, inter alia, the requirements for qualification as a possession corporation (i.e., a U.S. corporation that qualifies for the Puerto Rico and possession tax credit), the tax aspects of doing business as a possession corporation, and the effect of possession corporation status on its shareholders. The portfolio addresses the intercompany transfer pricing problems that confront possession corporations and their shareholders and affiliates, and provides a detailed discussion of some historic, complex, transfer pricing litigation concerning income from intangible property in the context of Puerto Rico. There is also a review of the history of the U.S. and Puerto Rican tax incentive systems. Finally, the portfolio discusses the very significant changes made to the possession corporation tax regime by the Revenue Reconciliation Act of 1993, which imposed major limitations on the operation of [section] 936, and the Small Business Job Protection Act of 1996, which repealed [section] 936 subject to a lengthy transitional period."

Formerly published in Washington, D.C., 2005-2007.

Includes bibliographical references.

Issued also in print.

Mode of access: World Wide Web.

Title from title screen (viewed Oct. 4, 2007).

www

Print version: Aud, Ernest F. Possession tax credit under section 936. [Washington, D.C.] : Tax Management, c2005-

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