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Notice 90-27 stated that the IRS would promulgate regulations providing that BIG recognized on an installment sale occurring before or during the recognition period would be treated as RBIG, even if recognized after the recognition period.
Because the approach restricts the scope of items treated as built-in, loss corporations with NUBILs generally will opt to apply it; loss corporations with NUBIGs generally will not derive significant benefit from its use.
An "account balance plan" is essentially a defined contribution plan - one under which deferred amounts and additional amounts treated as income thereon are credited to a participant's account and the benefit payable from the plan is based solely on the participant's account balance.
Thus, the proposed regulations state that not all amounts denominated as "income" under the terms of a plan are treated as such and impose limitations on the extent to which additional amounts credited to an employee's account are in fact treated as income exempt from FICA taxes.
If a partnership or corporation makes a gratuitous transfer to a trust, the partners or shareholders will be treated as the grantors, unless the transfer is made for a business purpose of the partnership or corporation (Temp.
Generally, the transferor trust's grantor, rather than the transferor mast, will be treated as the transferee trust's grantor.
An entity type on the list is automatically treated as a corporation for Federal tax purposes).
As noted, new FEEs on the per se list are automatically treated as corporations for Federal tax purposes; thus, hybrid status is not available for such entities.
If a domestic eligible entity makes no election, it will be treated as a partnership if it has more than one owner and disregarded if it has only a single owner.
While an LLC formed under California law must have two or more owners, the new law permits non-Californian SMLLCs to check-the-box to be treated as a disregarded entity.
707 (a)(2)(A) provides, in relevant part, that of (1) a partner transfers property to a partnership, (2) there is a related direct or indirect allocation and distribution to such partner, and (3) when (1) and (2) are viewed together,they are property characterized as occurring between a partnership and a partner acting in other than his capacity as a partner, the transfers will be treated as a sale or exchange of property.
Under this approach, a contribution of property followed by a distribution from the partnership will not be treated as a disguised sale if the contributing partner is merely converting equity in the contributed property into an interest in partnership capital that is subject to the entrepreneurial risks of partnership operations.