Under the proposed Interpretation, since no individual project satisfies
a "probable" level of confidence of being sustained, the enterprise would record no benefit.
In Situation 2, A is covered by an HDHP, a health FSA and an HRA that pay or reimburse medical expenses incurred before A satisfies
the minimum annual deductible under Sec.
2001-43 treats the grant of this interest just like a grant of a vested profits interest, if (1) the partnership and service provider treat the latter as a partner from the grant date of the substantially nonvested profits interest, (2) no one takes a deduction for such interest and (3) the taxpayer satisfies the Rev.
2001-43, the Service treats a person receiving a substantially nonvested profits interest as receiving the interest on the grant date if that person satisfies the three requirements.
However, the research related to the development of the new heating element, a subset of the improved toaster, satisfies
all three qualified research requirements under Sec.
Thus, a line of business may be dominant if at least 25% of the employer's substantial-service employees are assigned to that line and the line satisfies
certain other conditions.
A more difficult issue is whether a taxpayer satisfies the exclusive use requirement when he uses a home office for both qualifying and nonqualifying business purposes.
Since the gross income limitation applies only if the home office satisfies the exclusive use requirement, this example implies that using a home office for nonqualifying business purposes does not preclude a deduction with respect to a qualifying business use.
280A(c)(1), the Tax Court concluded that a taxpayer satisfies the exclusive use requirement only if each and every business use is qualifying.
treaties, generally allow a company resident in either the United States or the Netherlands to obtain treaty benefits if it meets one of four objective tests, or if the competent authority of the source country determines that the company satisfies
a subjective test.
401(a)(4), 410(b) and 414(s) must show that there is a high likelihood that the plan satisfies the nondiscrimination requirements.
Quality of data: An employer that does not have precise data available at a reasonable cost to substantiate that its plan satisfies the nondiscrimination requirements may use less-than-precise data, provided the following conditions are met.