* The arrangement is entered into
in connection with the performance of services and the employee or service provider is not the insurance contract's owner; or
Group C: Group C taxpayers believe that, while the aggregate approach was desirable from a business perspective, a valid hedging transaction could only be achieved for tax purposes where the member with the risk entered into
a risk-reducing transaction with a third party or another member of the group that was an HC.
According to the IRS, the agreements entered into
by the parties required the taxpayer to consent to each stock loan.
1, 200 the two groups entered into
a buy-out agreement, which called for the Hadars to pay Blue Chip $23.4 million for their portion of the property, according to the Hadar suit.
The temporary and proposed regulations were generally effective with respect to hedging transactions entered into
in all previous open tax years, provided certain identification requirements were met.
has entered into
a relationship with Symbol Technologies, a company active in bar-code scanning systems, to provide vendor-approved software and hardware offerings for many of its products.
transferor remained in existence, a GILA may be entered into
only if the (1) U.S.
To attain beneficial treatment for hedging transactions entered into
after December 31, 1993, taxpayers must identify the transactions (in their books and records) before the close of the day the transaction is entered into
Thus, statutory, regulatory, and case law governing the completed contract method still has relevance for (1) all contracts enterd into befor February 28, 1986, (2) 60 percent of ocntracts entered into
from February 28, 1986, through October 13, 1987, (3) 30 percent of contracts entered into
after October 13, 1987, and (4) all real property contracts meeting the requirements of section 460(e).
If the foreign insurer or reinsurer has entered into
a closing agreement, that person must file Form 720 and pay any tax due; die premium payer is exempt from any filing requirement under these circumstances.
Alexander's also announced that it had entered into
an agreement with the Official Committee of Unsecured Creditors on terms for an extension of up to March 31, for the final payment of approximately $28 million due general unsecured creditors under the company's plan of reorganization.
David's entered into
the HCA joint venture, it was no longer engaged in activities that principally furthered any charitable purpose.