Tag Archives: BR

Brackets

Brackets

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Bracket Creep

The edging into higher tax brackets that occurs as income rises with inflation. Bracket creep increases government revenue without tax increases. The Tax Reform Act of 1986 virtually ended bracket creep by taxing individuals in only two brackets beginning in 1988 and adjusting the brackets for inflation after 1988. Subsequent tax acts, however, have increased the number of brackets.

U.S. and other Developed Countries International Tax Meaning

Term used in connection with graduated system of taxation to refer, for example, to the slabs or slices of taxable income subject to particular rates of income tax.

See the entries Income Tax and State Income Tax in the American Encyclopedia of Law.

Broker

Broker

Broker means:
any person who, in the ordinary course of business, stands ready to effect sales between other parties. Former Tax Regulation (check if this Reg. is current here) §1.6045-1 (a)(1). A broker is required to prepare and send to the U.S. Internal Revenue Service an information return for each sale by a customer effected by the broker. Former Tax Regulation (check if this Reg. is current here) §1.6045-1 (c)(2).

Branch Profits Tax

Branch Profits Tax

About Branch Profits Tax:

A BPT is a tax of 30% of the dividend equivalent amount, imposed on foreign companies doing business in the United States. The dividend equivalent amount is the foreign corporation's effectively connected earnings and profits for the tax year, subject to certain adjustments for increases and decreases in net equity. Effectively connected earnings and profits are the earnings and profits (or the deficit) attributable to income that is effectively connected with the conduct of a trade or business in the United States. Former IRC (check if this IRC provision is current here) §312; Former Temporary Regulation (check here if this Temp. Reg. is current) §§1.884-lT(b)(2) and 1.884-2T.

See also other Tax Terms and Definitions in U.S.A.

effectively connected income.

U.S. and other Developed Countries International Tax Meaning

See: Branch tax.

See Dividend in the American Legal Encyclopedia and Dividend in the World Legal Encyclopedia.

Brother-sister Controlled Group of Corporations

Brother-sister Controlled Group of Corporations

The Brother-sister Controlled Group of Corporations are.

two or more corporations owned by the same shareholder(s). Five or fewer persons must own at least 80% of each corporation. Former IRC (check if this IRC provision is current here) § 1563(a)(2).

See also other Tax Terms and Definitions in U.S.A.

attribution rules.