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Under the second part of the two part test, amounts paid to investigate or otherwise pursue a covered transaction (regardless of whether they are inherently facilitative amounts) are treated as amounts incurred to facilitate a covered transaction and must be capitalized if they are incurred on or after a certain date (referred to here as the bright-fine date) (see Regs.
In addition, as noted in our January 2013 letter, the 70-30 safe harbor for success-based fees can lead to under- or overcapitalization of facilitative fees.
Leading Schools for Systems Development: The Role for Facilitative Leadership
Jones and colleagues' (Jones, Meijen, McCarthy, & Sheffield, 2009), a theory of challenge and threat states in athletes, hypothesizes that individuals with greater perceptions of control in stressful sport situations perceive anxiety as facilitative and show differences in cardiac activity from those who see the situation as a threat.
Helping the two parties to hear what each other is saying is one way to be facilitative, but there is another, equally important, way to improve communication: keep the discussion on track.
Because the Transaction Cost Regulations do not require a taxpayer undertaking a covered transaction to capitalize amounts incurred for non-inherently facilitative activities performed before the bright line dale, a taxpayer must analyze whether such costs are deductible or amortizable under IRC sees.
What, then, is the inference pattern Raz relies on to generate both the Detachment Argument and the Facilitative Principle?
The year 2 professional fees of $900,000 are category 6 transaction costs because they are incurred for services performed on or after January 1, year 2, and they are facilitative.
Yet, it is possible that the cognitive and somatic components as assessed by the ARS-2 were interpreted as facilitative by some athletes and deb ilitative by others, thus did not discriminate match outcome with these participants.
The role of managers is changing away from a directive (or command and control) orientation to a facilitative (or coach and counsel) role and, further, to an enabling (or empowering) role.
A facilitative environment for integrating the stock exchanges in Pakistan is therefore provided in the Demutualization Act.
Using the Facilitative Leader Approach to Create an Organizational Culture of Collaboration (Roger Schwarz)

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