The corporation allocates
total workers' comp costs in proportion to the division's share of total lost days for the entire corporation.
According to the ILLS, the taxpayer was not using a burden rate method, because it did not allocate
costs to specific inventory items.
162-29(c)(6) should be revised to state that the taxpayer must allocate
the travel costs to lobbying only if a substantial purpose of the trip was for lobbying.
A donor therefore cannot allocate
GST exemption to a grantor retained annuity trust or qualified personal residence trust--where the trust property is included in her gross estate if she dies before her retained interest in the trust terminates--until the estate tax inclusion period ends (when the grantor dies, a generation-skipping transfer occurs with respect to the property, or the grantor's retained interest in the trust expires).
Under a traditional ESOP, an ESOP trust borrows money to buy stock, holds the stock as collateral in a suspense account and allocates
it over the term of the loan according to one of the formulas Treasury regulations permit.
861-10T(c) contains a new rule for integrated financial transactions that allocates
interest expense directly to income from an investment funded with amounts borrowed for the purpose of acquiring the investment.
While the rules probably do correct the failure to properly allocate
the exemption to trusts meant to benefit skip persons, they can also result in wasting the GST exemption, by automatically allocating it to trusts not intended to benefit skip persons.
the BIG or BIL to the contributing partner.
tolerable misstatement using our approach, a Delphi team is selected.
The Internal Revenue Service allocated rents to Central de Gas under section 482, which grants it authority to allocate
items of income and expense among related parties to reflect income properly.