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This is because neither the partnership nor the disregarded entity owned by the partnership qualifies as a combining entity.
17) </pre> <p>The taxpayer in this example is required to shrinkback the shoe to the portion of property that qualifies as an item, which, in the example, is the sole of the shoe.
The roasting of coffee beans qualifies as a production activity, but a taxpayer that roasts beans and then serves coffee made from them in the store is engaged in both manufacturing and nonmanufacturing activities.
Provided the hedge qualifies for hedge accounting under SFAS 52, the parent should record the hedge's marked-to-market adjustments directly to stockholders' equity (that is, the current translation account).
565 per share (33%) qualifies as ordinary taxable income
04(7)(d) of Notice 2005-14, which provides that software delivered to customers by downloading the software from the Internet qualifies for the section 199 deduction whereas gross receipts from software offered for use online does not qualify as domestic production gross receipts.
However, in most cases, the planner recommends that the trust not be named as a beneficiary of either the decedent's share of a pension plan or IRA accounts; unless the trust qualifies as a "look-through" trust, the heirs will be required to receive and be taxed on the entire pension benefits within a five-year timeframe; see Sec.
If stock in any corporation is acquired solely through the conversion of stock which qualifies under Sec.
A family-owned business interest qualifies for relief if it is a trade or business interest in either a proprietorship or an entity of which 50% is owned by the decedent and members of his or her family, 70% is owned by members of two families or 90% is owned by members of three families.
For example, the Downtown Business Alliance, working with the New York City Partnership, is spearheading an effort to create a home for the software industry Downtown which is predicated, in part, on the Department of Finance determining that such a use qualifies for "industrial" strength ICIP benefits under which the full value of any physical increase will be exempt from taxation for thirteen years, and thereafter added to the taxable assessed value in increments of 10 percent per year until fully included in the 23rd year.
SAN FRANCISCO & TORONTO -- Eloqua Conversion Suite Qualifies Prospects and Delivers Best Leads to Salesforce.
The term "qualified" refers to the fact the plan qualifies for favorable tax treatment.