In either case, the general intent of the FIE Rules is to ignore shares and debt owned by an NRE in its affiliates for purposes of the 50-percent investment property test, and to deem
the NRE to own a proportional amount of the affiliates' assets.
6513(b)(1), however, deems
the payment of the tax to which the refund claim relates to have occurred on April 15, 1998, which is beyond the period of three years plus the four-month extension immediately preceding Aug.
an affiliate's income from the sale of property to be included in FAPI.
In the event that during the Extraordinary General Shareholders' Meeting alternative proposals are presented on the business included on the Agenda and they are submitted to voting, the proxyholder shall exercise the vote in the sense he deems
most favorable to the interest of the grantor shareholder.
One of the principal nontax reasons for buying assets (as opposed to the stock) of a target corporation (T) is that a purchaser (P) can exclude pre-acquisition liabilities from the purchase, and generally acquire only those assets (and liabilities) it deems
appropriate for its business.
8) The recently proposed changes to the regulations under section 446 confirm the IRS's administrative practice of imposing any conditions it deems
proper for approving a change in accounting method.
EXACT Sciences Corporation (NASDAQ: EXAS) announced today that David Deems
has joined the Company as Vice President of Product Development.
This causes great concern for small organizations, which could be spending a small amount of time and money on a legislative initiative (which it deems
is insubstantial) and yet could be deemed
to have a great impact on the organization once the new law is enacted.
Consistent with previously announced ABIOMED policy for the AbioCor initial clinical trial, additional information about the patients will be made available when the clinical team deems
it to be clinically significant or a patient's family deems
it to be appropriate.
If a state deems
an SMLLC a DE, shifting ownership of an SMLLC without significant operations in a state to a tax reporting entity in that state may inflate the denominator of the state's apportionment factor without a corresponding increase in the numerator.
Cardiac Science will continue to evaluate its holdings in Spacelabs and, depending upon market conditions, further communications with Spacelabs and other factors which the company deems
relevant, it may sell some or all of those shares.
The MDIB rule deems
the designated beneficiary (other than the participant's spouse) to be no more than 10 years younger than the employee while the employee is alive, which increases the payout amount until the employee dies.