Description of Tax Provisions Expiring in 1990 Jcs-5-90
Description of Tax Provisions Expiring in 1990 Jcs-5-90
United States. Congress. Joint Committee On Taxation
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source income, 64 percent of foreign-incurred R&D expenses were allocated to foreign source income, and the remainder of R&D expenses were allocated and apportioned either on the basis of sales or gross income, but subject to the condition that if income-based apportionment was used, the amount apportioned to foreign source income could be no less than 30 percent of the amount that would have been appor- tioned to foreign source income had the sales method been used. For expenses deemed to have... been incurred during the remaining 15 eight (or fewer) months of the year governed by TAMRA, the R&D allocation regulation applied. Pursuant to the Omnibus Reconciliation Act of 1989 (OBRA), R&D expenses incurred during a taxpayer's first taxable year be- ginning after August 1, 1989 and before August 2, 1990 are treated in one of the same two alternative ways as they were under TAMRA, depending on whether the expenses were in effect deemed to have been incurred in the first nine months of the year, or in- curred instead during the remaining three or fewer months of the year.
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