Liability for amounts. equivalent to tax— (1) In general. A domestic corpora- tion which has entered into an agree- ment (as provided in § 36.3121(l) (1) 1, or any amendment thereof (as provided in (1) 2, incurs liability under the agreement in respect of certain re- muneration paid by each foreign sub- sidiary named in the agreement, or any amendment thereof. Liability is in- curred in respect of the remuneration paid to all those employees of the for- eign subsidiaries who are citizens of the United States and who perform services outside the United States (other than services which constitute employment) for the foreign subsidi- aries. However, liability is incurred only with respect to that portion of such remuneration paid by the foreign subsidiary which is attributable to services performed during the period for which the agreement is in effect with respect to such subsidiary, and then only to the extent that the remu- neration would constitute wages if the services to which the remuneration is attributable were performed in the United States. Liability with respect to such remuneration is incurred in an amount equivalent to the sum of the employee and employer taxes which would be imposed by sections 3101 and 3111, respectively, if such remuneration constituted wages. If an individual per- forms services for more than one of the foreign subsidiaries named in an agree- ment, including any amendment there- of, such services are regarded as being performed in the employ of a single employer for purposes of determining the amount of the remuneration for such services which would constitute wages if the services were performed in the United States. See § 36.3121(l)(9)–1, relating to the treatment of a domestic corporation as a separate entity in its capacity as a party to an agreement.
Appears in 5 contracts
Samples: Agreement Amendment, Amendment of Agreement, Agreement
Liability for amounts. equivalent to tax—
(1) In general. A domestic corpora- tion which has entered into an agree- ment (as provided in § 36.3121(l)
(1) 136.3121(l)(1)–1, or any amendment thereof (as provided in
(1) 2in § 36.3121(l)(1)–2, incurs liability under the agreement in respect of certain re- muneration paid by each foreign sub- sidiary named in the agreement, or any amendment thereof. Liability is in- curred in respect of the remuneration paid to all those employees of the for- eign subsidiaries who are citizens of the United States and who perform services outside the United States (other than services which constitute employment) for the foreign subsidi- aries. However, liability is incurred only with respect to that portion of such remuneration paid by the foreign subsidiary which is attributable to services performed during the period for which the agreement is in effect with respect to such subsidiary, and then only to the extent that the remu- neration would constitute wages if the services to which the remuneration is attributable were performed in the United States. Liability with respect to such remuneration is incurred in an amount equivalent to the sum of the employee and employer taxes which would be imposed by sections 3101 and 3111, respectively, if such remuneration constituted wages. If an individual per- forms services for more than one of the foreign subsidiaries named in an agree- ment, including any amendment there- of, such services are regarded as being performed in the employ of a single employer for purposes of determining the amount of the remuneration for such services which would constitute wages if the services were performed in the United States. See § 36.3121(l)(9)–1, relating to the treatment of a domestic corporation as a separate entity in its capacity as a party to an agreement.
Appears in 1 contract
Samples: Service Agreement