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I]n the case of a failure to report required information with respect to a foreign corporation, partnership, or trust, the statute of limitations with respect to any event or period to which such information relates [shall] not expire before the date that is three years after the date on which such information is provided.
In addition, the proposed regulations require that there be maintained financial and other documents filed with a foreign government entity, independent commission, or financial institution that relate to transactions between the reporting corporation and the foreign related party.
Rather, the critical consideration is whether such activity relates to the development, improvement, or testing of the functional design or specifications of a product or process.
The investment must not relate to, or be made in the normal course of, the trade or business of the taxpayer or any related person (which includes any contribution or loan to an employee stock ownership plan defined in section 4975(e)(7) or other qualified plan under section 401(a)).
1221-2(e)(3)(iv), if the hedging transaction relates to aggregate risk, the identification must include a description of the risk being hedged and the hedging program under which the transaction was entered.
The statutory authorization relates to a loss sustained by a corporate lender on repayment of a foreign currency denominated loan by a affiliated corporation.
The ruling does not address the subject of "tax advice" as it relates to sole proprietors, farmers or persons with supplemental income.
1274(d))beginning on (1)the date the partnership liability to a creditor or other person to whom the obligation relates becomes due and payable (for payment obligations) or (2) the date of the liquidation of the partner's interest in the partnership (for contribution obligations), no discounting is required.