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Furthermore, although section 461(d) was aimed at the problem of accruing two years' tax in one year, the language of the section itself is broader in that it applies to any action that will accelerate tax.
The court stated, however, that failure to declare the loan in default precludes the taxpayer from not accruing interest or deviating from the stated term of the contract.
Therefore, even though a corporation may have properly planned for the unrealized built-in gain with respect to its receivables by accruing additional compensation to its shareholder-employees to offset it, the recognized built-in gain from these receivables becomes inflated on collection.
Variables in mortgage-backed securities include the market value of the remaining balance, interest accruing throughout the current interest period, any accrued principal from prior months and any accrued interest from prior interest periods," explained Dr.
therefore, interest accruing at unreasonable rates may be considered compensation.
In addition, GTS announced that it has amended the indenture to provide for payment of interest accruing from January 15, 2000, to but not including the redemption date to any holder of bonds that converts prior to the redemption date.
Since 1982, however, the IRS's position, as expressed in GCM 38864, has been that only rehabilitation deductions and losses excluded from the definition of built-in deductions are those economically accruing in postaffiliation years.
871(a)(1)(C)(i) or 881(a)(3)(A), tax is imposed on the amount of OlD accruing while such obligation was held by the foreign investor who receives the retirement proceeds.