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In analyzing the effect of these rules on various transactions, the new regulations have examples that refer to combining entities, combining units and transferor units.
In general, sections 6011, 6111 and 6112 of the Internal Revenue Code provide "tax shelter" rules that require disclosure, registration, and list maintenance for certain transactions.
Decisions on incoterms, without the involvement of the transaction tax specialist, could be a financial risk, and failure to use incoterms to help structure tax-efficient international transactions could be an opportunity missed.
Crucial to the debate is the difficulty of clearly distinguishing between transactions that are abusive and transactions that are legitimate.
Workpapers supporting this evaluation often contain sensitive information about contingent or potential liability for transactions whose tax treatment may not be self-evident.
While electronic commerce offers speed, convenience, and cost advantages over traditional paper-based transactions, it raises many business and legal issues.
In California, businesses have been subject to, and governed by, the California Electronic Transactions Act since late 1999.
Conventional techniques to perform a point in time recovery will remove the effects of all transactions since that specified point in time.
Such a response would create artificial incentives to structure transactions on the basis of regulatory rules rather than of the economic characteristics of the transactions themselves.
Abusive tax transactions involving exempt organizations are especially troubling because nonprofits, particularly charities, are seen as doing social good and relieving the burden of government.
For corporate taxpayers, the penalty is $200,000 for so-called listed transactions (LTs), including transactions "substantially similar" to a listed transaction; and $50,000 for all other RT categories.
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- trample on
- trample upon
- tranquil mind
- transact business
- transact business with
- transact with
- transcript of minutes of commitment
- transcript of testimony
- transfer again
- transfer agent
- transfer among the living
- transfer back
- transfer by writing
- transfer control to the government
- transfer for a consideration
- transfer for sale
- transfer in contemplation of death
- Transfer of Assets
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- Transactional Interpretation of Quantum Mechanics
- Transactional Learning Environment
- Transactional License Program
- Transactional License Program Education
- Transactional License Program Government
- Transactional Metamodel for Business Process
- Transactional Multidimensional Data Model
- Transactional Net Margin Method
- Transactional Net Promoter Score
- Transactional Ntfs
- Transactional Object Model
- Transactional or Relationship Message
- Transactional Privilege Tax
- transactional psychotherapy
- Transactional Records Access Clearinghouse
- Transactional Registry
- Transactional Remote Function Call
- Transactional Reporting Service
- Transactional Shared Property Manager
- Transactional Shared Service Center
- transactional software
- Transactional Track Record
- Transactional Tracking System
- Transactions and Proceedings of the American Philological Association
- Transactions By Others
- Transactions Cost
- Transactions costs
- Transactions demand
- Transactions Electroniques Sécurisées
- Transactions et Locations Immobilières
- Transactions For Others
- transactions in external assets and liabilities
- Transactions motive
- Transactions Motives
- Transactions of the American Geophysical Union
- Transactions of the American Mathematical Society
- Transactions of the American Philological Association
- Transactions of the American Philosophical Society
- Transactions of the Asiatic Society of Japan
- Transactions of the Bristol and Gloucestershire Archeological Society
- Transactions of the Cambridge Bibliographical Society
- Transactions of the Gaelic Society of Inverness
- Transactions of the Historic Society of Lancashire and Cheshire
- Transactions of the Institute of British Geographers
- Transactions of the Institute of Metal Finishing
- Transactions of the Jewish Historical Society of England
- Transactions of the Leicestershire Archaeological Society
- Transactions of the Literary and Historical Society of Quebec
- Transactions of the New Zealand Institute
- Transactions of the Oriental Ceramic Society
- Transactions of the Royal Historical Society
- Transactions of the Royal Martian Geographical Society
- Transactions of the Society of Biblical Archaeology