Because of the many newly created or converted S corporations, many letter rulings, notices, proposed regulations and revenue procedures reflected the 1996 legislative changes regarding qualified subchapter S subsidiaries (QSSSs), qualified subchapter S trusts (QSSTs) and electing
small business trusts (ESBTs); in addition, Rev.
The net effect of electing
to amortize the market discount for tax-exempt bonds is that the taxpayer can treat the entire gain as a capital transaction (as opposed to a mixture of capital gain or loss and ordinary income).
If the spouse dies prematurely, electing
not to recalculate on the spouse's life will guarantee continued payout over a longer joint life expectancy.
To address this problem, the Service requires a taxpayer electing
a different method of accounting for real estate taxes to elect one of two approaches to convert from one accounting method to another: (1) a cut-off approach or (2) a full-year change approach.
The Sixth Circuit reversed, holding that the date for determining whether a power of appointment exists is the date of electing
Constitution created a two-step process for electing
the leaders of which branch of government?
For example, in the state Senate, instead of electing
40 individual district seats, we could elect 10 districts with four seats each, elected by a proportional method where a party's candidates wins legislative seats in proportion to their percentage of the popular vote.
large LLC must designate a member or other person who has the sole authority to act on behalf of the entity under the electing
large LLC audit procedures.
Also, the final regulations simplify the filing requirements of an electing
trust, as well as the procedures for furnishing a taxpayer identification number to payors.
MTNA members will be electing
Division officers and directors beginning in February 2004.
In addition to electing
the fixed-numberof-years method, the IRA owner also can enter into a separate agreement with the IRA custodian providing for certain taxplanning deferral arrangements that do not violate the required minimum distribution rules of section 401(a)(9).
According to this argument, the framers of Article 11 and of the 12th Amendment (which set out the process for electing
a president) gave Congress a quasi-judicial checking function, ensuring that electoral ballots are valid.