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First, TEI recommends permitting the recognition of benefits for tax positions that satisfy the applicable legal threshold necessary to avoid the imposition of statutory penalties for underpayment of taxes.
If properly executed, the strategy helps to ensure that variety-seekers do not have to switch to a different manufacturer to satisfy their desire for change.
In performing the ACP Test, employer matching contributions and employer nonelective contributions used to satisfy the safe harbor rules may not be taken into account for purposes of the ACP Test.
Consequently, the transaction will satisfy the requirements of Regs.
Because the criteria to satisfy these three requirements relate to the less-difficult ones, companies that meet them usually satisfy the others.
Satisfy the nontransferability requirements of section 401(g), if applicable.
To satisfy this safe harbor, the separate line of business must simply operate within a different industry or industries from those of the employer's other lines of business.
Borrowing from commercial sources on reasonable commercial terms in an amount sufficient to satisfy the need.
Having ascertained that the three members' operations satisfy the elements of cooperative operation, the Service concluded that the U.
In addition to the requirements related to the FSC itself, the export property must satisfy certain requirements to qualify for FSC benefits.