Tax advantage definition limits accounting allowances and arrangements that create excess profits for tonnage tax companies. Section 115VZB treats tax advantage as arising where accounting determinations of allowances, or allocations or apportionments of costs or expenses recorded in the books for the year of the transaction, reduce income or increase loss from non tonnage tax activities; and where a transaction or arrangement yields a tonnage tax company more than ordinary profits expected from tonnage tax activities.
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Provisions expressly mentioned in the judgment/order text.
Tax advantage definition limits accounting allowances and arrangements that create excess profits for tonnage tax companies.
Section 115VZB treats tax advantage as arising where accounting determinations of allowances, or allocations or apportionments of costs or expenses recorded in the books for the year of the transaction, reduce income or increase loss from non tonnage tax activities; and where a transaction or arrangement yields a tonnage tax company more than ordinary profits expected from tonnage tax activities.
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