The consideration B received in the form of the liability C assumed ($30,000) is offset by the consideration B gave by assuming the $20,000 liability; the net amount, $10,000, is treated as
money or other property.
As "property other than stock," the NQPS will be treated as
"boot" and, hence, the recipients will be taxed on the value of NQPS.
382(h)(6)(A), any item of income properly taken into account during the recognition period is treated as
recognized built-in gain (RBIG) if the item is attributable to periods before the change date.
An "account balance plan" is essentially a defined contribution plan - one under which deferred amounts and additional amounts treated as
income thereon are credited to a participant's account and the benefit payable from the plan is based solely on the participant's account balance.
investor uses any PFIC stock as security for a loan, the investor would be treated as
having disposed of such stock.
Therefore, filing a Form 1099 may establish that a taxpayer did not"treat" a corporate officer as an employee (when that filing was consistent with its treatment of the officer as a nonemployee in other nonfiling contexts, and when other individuals with substantially similar positions were not treated as
an attorney for a client) will not be treated as
the owner of any portion of the trust if the accommodation party is reimbursed within a reasonable period of time, although such party will be treated as
a grantor for purposes of reporting transfers to foreign trusts.
A "hybrid" is a foreign entity taxable as a corporation in its country of incorporation that chooses to be treated as
a partnership or a branch for Federal tax purposes.
1361 (b)(3), the qualified subchapter S subsidiary (QSSS) is considered a division of the parent corporation; all of its assets, liabilities, income, expenses and credits are treated as
belonging to the parent.
The Service ruled that the merger would be treated as
1) Under the FCBRs, entities not automatically treated as
corporations (referred to as"eligible entities") may elect their Federal tax classification.
1491, a domestic trust that becomes a foreign trust will be treated as
having transferred all of its assets to a foreign trust.