Epstein Files Search

EFTA00301255Set 9

2016-12-3148p19,426w

Section 937(6)(2) should be revised to eliminate anomalous outcomes and prevent U.S. base erosion, yet not needlessly encroach on the general ECI rule under Section ... business. Such a rule properly addresses Treasury's legitimate concerns about abuse and U.S. base erosion, while also giving full effect to the competing policy goal of promoting USVI economic

https://www.justice.gov/epstein/files/DataSet%209/EFTA00301255.pdf

EFTA02023134Set 10

2011-01-252p682w

conditions for such treatment in certain cases, section 881(b)(1XC) sets forth a "base-erosion" test requiring that no substantial part of the possessions corporation's income be used ... person satisfies the requirements of section 937(a). For purposes of the base-erosion test, §1.881-5T(fX4)(i) defines a bona fide resident of a possession by reference ... defines bona fide residents of the United States for purposes of the base-erosion test as including only certain individuals who are citizens or residents of the United States. Commentators

https://www.justice.gov/epstein/files/DataSet%2010/EFTA02023134.pdf

EFTA01833375Set 10

2011-01-252p650w

conditions for such treatment in certain cases, section 881(b)(1XC) sets forth a 'base-erosion' test requiring that no substantial part of the possessions corporation's income be used ... person satisfies the requirements of section 937(a). For purposes of the base-erosion test, §1.881-5T(fX4Xi) defines a bona fide resident of a possession by reference ... defines bona fide residents of the United States for purposes of the base-erosion test as including only certain individuals who are citizens or residents of the United States. Commentators

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01833375.pdf

EFTA00648459Set 9

2011-01-252p840w

conditions for such treatment in certain cases, section 881(bX1) (C) sets forth a "base-erosion' test requiring that no substantial part of the possessions corporation's income be used ... person satisfies the requirements of section 937(a). For purposes of the base-erosion test, §1.881-5T(f)(4)(i) defines a bona fide resident of a possession ... defines bona fide residents of the United States for purposes of the base-erosion test as including only certain individuals who are citizens or residents of the United States. Commentators

https://www.justice.gov/epstein/files/DataSet%209/EFTA00648459.pdf

EFTA00648497Set 9

2011-01-252p681w

conditions for such treatment in certain cases, section 881(bX1) (C) sets forth a "base-erosion' test requiring that no substantial part of the possessions corporation's income be used ... person satisfies the requirements of section 937(a). For purposes of the base-erosion test, §1.881-5T(f)(4)(i) defines a bona fide resident of a possession ... defines bona fide residents of the United States for purposes of the base-erosion test as including only certain individuals who are citizens or residents of the United States. Commentators

https://www.justice.gov/epstein/files/DataSet%209/EFTA00648497.pdf

EFTA01799691Set 10

2011-01-253p829w

person satisfies the requirements of section 937(a). For purposes of the=base-erosion test, §1.881-5T(f)(4)(i) defines a bona fide resident of a =ossession ... defines bona fide reside=ts of the United States for purposes of the base-erosion test as including=only certain individuals who are citizens or residents of the United State ... comment=tors further noted that many common business arrangements would run afoul =f the base-erosion test if corporations cannot constitute bona fide reside=ts. The IRS an= Treasury agree

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01799691.pdf

EFTA01383052Set 10

1p724w

Fund or such subsidiary could be subject to significant taxation in such jurisdiction. Base Erosion and Profit Shifting The Organization for Economic Co-operation and Development (the "OECD) together with ... countries has committed to reduce perceived abusive global tax avoidance, referred to as base erosion and profit shifting (-REPS"). As part of this commitment, an action plan has been developed

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01383052.pdf

EFTA01355228Set 10

1p724w

Fund or such subsidiary could be subject to significant taxation in such jurisdiction. Base Erosion and Profit Shifting The Organization for Economic Co-operation and Development (the "OECD) together with ... countries has committed to reduce perceived abusive global tax avoidance, referred to as base erosion and profit shifting (-REPS"). As part of this commitment, an action plan has been developed

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01355228.pdf

EFTA01391156Set 10

2022-01-011p724w

Fund or such subsidiary could be subject to significant taxation in such jurisdiction. Base Erosion and Profit Shifting The Organization for Economic Co-operation and Development (the "OECD) together with ... countries has committed to reduce perceived abusive global tax avoidance, referred to as base erosion and profit shifting (-REPS"). As part of this commitment, an action plan has been developed

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01391156.pdf

EFTA01354292Set 10

2022-01-011p724w

Fund or such subsidiary could be subject to significant taxation in such jurisdiction. Base Erosion and Profit Shifting The Organization for Economic Co-operation and Development (the "OECD) together with ... countries has committed to reduce perceived abusive global tax avoidance, referred to as base erosion and profit shifting (-REPS"). As part of this commitment, an action plan has been developed

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01354292.pdf

EFTA01389384Set 10

2022-01-011p726w

Fund or such subsidiary could be subject to significant taxation in such jurisdiction. Base Erosion and Profit Shifting The Organization for Economic Co-operation and Development (the "OECD) together with ... countries has committed to reduce perceived abusive global tax avoidance, referred to as base erosion and profit shifting (-REPS"). As part of this commitment, an action plan has been developed

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01389384.pdf

EFTA01393380Set 10

2022-01-011p725w

Fund or such subsidiary could be subject to significant taxation in such jurisdiction. Base Erosion and Profit Shifting The Organization for Economic Co-operation and Development (the "OECD) together with ... countries has committed to reduce perceived abusive global tax avoidance, referred to as base erosion and profit shifting (-REPS"). As part of this commitment, an action plan has been developed

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01393380.pdf

EFTA01392453Set 10

1p725w

Fund or such subsidiary could be subject to significant taxation in such jurisdiction. Base Erosion and Profit Shifting The Organization for Economic Co-operation and Development (the "OECD) together with ... countries has committed to reduce perceived abusive global tax avoidance, referred to as base erosion and profit shifting (-REPS"). As part of this commitment, an action plan has been developed

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01392453.pdf

EFTA01389809Set 10

1p722w

Fund or such subsidiary could be subject to significant taxation in such jurisdiction. Base Erosion and Profit Shifting The Organization for Economic Co-operation and Development (the "OECD) together with ... countries has committed to reduce perceived abusive global tax avoidance, referred to as base erosion and profit shifting (-REPS"). As part of this commitment, an action plan has been developed

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01389809.pdf

EFTA01364806Set 10

1p724w

Fund or such subsidiary could be subject to significant taxation in such jurisdiction. Base Erosion and Profit Shifting The Organization for Economic Co-operation and Development (the "OECD) together with ... countries has committed to reduce perceived abusive global tax avoidance, referred to as base erosion and profit shifting (-REPS"). As part of this commitment, an action plan has been developed

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01364806.pdf

EFTA01393665Set 10

2022-01-011p723w

Fund or such subsidiary could be subject to significant taxation in such jurisdiction. Base Erosion and Profit Shifting The Organization for Economic Co-operation and Development (the "OECD) together with ... countries has committed to reduce perceived abusive global tax avoidance, referred to as base erosion and profit shifting (-REPS"). As part of this commitment, an action plan has been developed

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01393665.pdf

EFTA01353884Set 10

2022-01-011p725w

Fund or such subsidiary could be subject to significant taxation in such jurisdiction. Base Erosion and Profit Shifting The Organization for Economic Co-operation and Development (the "OECD) together with ... countries has committed to reduce perceived abusive global tax avoidance, referred to as base erosion and profit shifting (-REPS"). As part of this commitment, an action plan has been developed

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01353884.pdf

EFTA01386663Set 10

1p724w

Fund or such subsidiary could be subject to significant taxation in such jurisdiction. Base Erosion and Profit Shifting The Organization for Economic Co-operation and Development (the "OECD) together with ... countries has committed to reduce perceived abusive global tax avoidance, referred to as base erosion and profit shifting (-REPS"). As part of this commitment, an action plan has been developed

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01386663.pdf

EFTA01394233Set 10

2022-01-011p725w

Fund or such subsidiary could be subject to significant taxation in such jurisdiction. Base Erosion and Profit Shifting The Organization for Economic Co-operation and Development (the "OECD) together with ... countries has committed to reduce perceived abusive global tax avoidance, referred to as base erosion and profit shifting (-REPS"). As part of this commitment, an action plan has been developed

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01394233.pdf

EFTA01354721Set 10

2022-01-011p724w

Fund or such subsidiary could be subject to significant taxation in such jurisdiction. Base Erosion and Profit Shifting The Organization for Economic Co-operation and Development (the "OECD) together with ... countries has committed to reduce perceived abusive global tax avoidance, referred to as base erosion and profit shifting (-REPS"). As part of this commitment, an action plan has been developed

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01354721.pdf