In this situation, the
affiliated group would enjoy a double benefit from the exemption (i.
Hence, although taxpayers have in the past taken exception to the Department of Revenue's proposed treatment of royalties paid to
affiliated companies, there is scarcely a question among taxpayers that the Department is the proper State agency to address any perceived abuses in this area.
The Board proposed to reserve its authority to reimpose the funding, credit extension, and credit enhancement firewalls in the event that an
affiliated bank or thrift institution becomes less than well capitalized and the bank holding company does not promptly restore it to the well-capitalized level.
The following factors (listed in descending order of importance) will be considered in determining whether an organization is closely
affiliated with a governmental unit: * The organization is financially accountable to one or more governmental units that is, it is required - it does not just volunteer - to report to governmental units (at least annually) information comparable to that required on Form 990, and is subject to financial audit by the governmental units to which it reports--not just under a government grant or other contract).
subsidiaries wholly owned by two or more foreign corporations with a common parent corporation will also be considered members of an
affiliated group and thus one taxpayer for purposes of the earnings stripping provisions.
However, some firms were acquiring necessary voting power while much, if not most, of the value of the stock was in the hands of individuals or entities that were not part of the
affiliated group.
