Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
Whistleblower reward received from the U.S. Securities and Exchange Commission was held taxable as income, because section 2(24) is of wide amplitude and the payment arose from arranged pursuit of whistleblower claims, legal assistance on success-fee terms, collection of material, filing of the complaint, and cooperation in the investigation. The Tribunal found a clear element of expectation and quid pro quo, so the receipt was neither gratuitous nor a windfall or capital receipt. It further held that the one-time character of the payment did not make it capital, and that the amount was at least taxable as income from other sources under section 56(1).
Whistleblower reward received from the U.S. Securities and Exchange Commission was held taxable as income, because section 2(24) is of wide amplitude and the payment arose from arranged pursuit of whistleblower claims, legal assistance on success-fee terms, collection of material, filing of the complaint, and cooperation in the investigation. The Tribunal found a clear element of expectation and quid pro quo, so the receipt was neither gratuitous nor a windfall or capital receipt. It further held that the one-time character of the payment did not make it capital, and that the amount was at least taxable as income from other sources under section 56(1).
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