Chapter 3

A law written and passed by a legislative body.

Sources of tax law, including the Internal Revenue Code, U.S. Constitution, and international tax treaties.

The Constitution, tax treaties, and the Internal Revenue Code are the statutory sources of the federal tax law. They have the presumption of correctness unless a court modifies or overturns a provision in response to a taxpayer challenge. In this regard, legislative intent and history can be important in supporting the taxpayer's case.

A position taken on a tax return that is without merit and not supported by legislative, administrative, or judicial sources of law.

An act of Congress that addresses the application of certain Internal Revenue Code provisions to a taxpayer whose tax base falls under the taxing statutes of more than one country. Published in the Internal Revenue Bulletin, among other resources. Generally, treaties are negotiated to prevent double taxation by providing reduced tax rates or exempting certain types of income from taxation. The income receiving reduced rates, tax holidays, and exemptions vary among countries.

Another name for a tax treaty. There are two influential model tax ...s-the United Nations and OECD Model ...s.

In reference to tax treaties, a .. is an agreement that diplomatic negotiators formulate and sign as the basis for a final convention or treaty.

In reference to tax treaties, a guide to help understand the treaty and the policies behind treaty provisions, as well as agreements reached during the negotiations with respect to the application and interpretation of the treaty.

In reference to tax treaties, a document prepared by the Senate Foreign Relations Committee.

The committee of the U.S. House of Representatives that deals with matters of taxation.

The committee of the U.S. Senate that deals with matters of taxation.

A committee formed to reconcile differences in versions of a tax bill passed by the U.S. House of Representatives and U.S. Senate.

A summary of the issues that were considered by the House Ways and Means Committee, Senate Finance Committee, or Joint Conference Committee, here relative to proposed or adopted changes in the language of the Internal Revenue Code. Useful in tax research as an aid to understanding unclear statutory language and legislative history or intent. Published in the Internal Revenue Bulletin.

The primary statutory source of the federal tax law, a collection of laws that have been passed by Congress and incorporated in Title 26 of the U.S. Code. The code was last reorganized in 1954. It is presently known as the ... ... ... of 1986. The chief subdivision of the code is the section.

Language in the Internal Revenue Code that does not appear to be associated with any particular subsection, paragraph, or other element of the section.

Legislation that is designed to correct errors in existing law in order to fully implement the intended policies of previously enacted legislation.

Sources of tax law, including the Internal Revenue Code, U.S. Constitution, and international tax treaties.