Tag: Allocation of income

The apportionment or assignment of income for various tax purpose, e.g., between permanent establishments in various jurisdictions

US vs. National Semiconductor, May 1994, United States Tax Court

US vs. National Semiconductor, May 1994, United States Tax Court

National Semiconductor appealed an IRS ruling pertaining the allocation of income from its Asian subsidiaries. In this decision, the United States Tax Court upheld the IRS ruling. US-NatlSemi_decision_05021994 ... Continue to full case