An option contract provides one party (the option holder) with a right, but not an obligation, to buy or sell an underlying
financial instrument, foreign currency or commodity at an agreed-on price on or before a set date.
When the transaction matures, you'll have to set those flows so that those bonds, or whatever the underlying
fixed incomes are, don't expose you to principal risk at maturity.
Woolworth, the Court applied Mobil's underlying
unitary standard in the same manner as in ASARCO by focusing on whether there was functional integration between the taxpayer-parent and the nontaxpayer subsidiaries.
Nearly every cooperative has an underlying
mortgage, with terms generally set at 10 years.
In contrast, a generic rule (suck as proposed above) would bring clarity to this area, thereby furthering the policy goals underlying
the Code's charitable contribution provisions.
Observation: It is unclear whether the IRS reached the result in revenue ruling 91-32 because it felt compelled to do so by the policies underlying
the applicable statutory provisions or because it was trying to reach a taxable result.
311 should be based on the value of the underlying
assets transferred by P&T to the partnership.
Low ownership occupancy ratios and a high underlying
mortgage created severe sales difficulties.
1) A state member bank is authorized to invest in the asset underlying
Example: Parents M and F establish a valid FLP, which has $1,000,000 of underlying