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This is because neither the partnership nor the disregarded entity owned by the partnership qualifies as a combining entity.
As previously noted, this is true even in the case of a partnership that qualifies as an EAG partnership.
Debt secured by a qualified residence and used to refinance the home acquistion debt also qualifies as home acquisition debt, but only to the extent of the old mortgage principal balance immediately before refinancing.
Without the third-party commitment, a company must assess whether the intercompany commitment qualifies as firm.
Hastings' direct payment of Sally's tuition to Private College qualifies as educational assistance under the qualified EAP even though it is not directly related to her current job, and, in fact, qualifies her for a new trade or business.
An activity that qualifies as R&E under the section 174 regulations must meet the following three additional general requirements to be eligible for the section 41 credit: