Further, under the trust instrument, the trust was merely a conduit with respect
to such installment payments for the term of the surviving spouse's life.
Under section 3713(a) of the Senate bill, the IRS would be precluded for six months from issuing temporary or final regulations with respect
to Notice 98-11, which concerns the application of the Subpart F rules of the Code to so-called hybrid entities (i.e., an entity that is treated as a controlled foreign corporation for U.S.
If both a disposition and a deconsolidation occur with respect
to a share in the same transaction, the LDR applies first and then the deconsolidation rules apply, if necessary.
Is it reasonable to expect that a taxpayer who fails the diligence required with respect
to transactions that generate positive adjustments nevertheless will have been diligent for other transactions?
Neither of these provisions, however, states or implies that a separate carryback period exists with respect
to the AMT NOL.
Such an under-taking is a time-consuming and daunting task with respect
to shares in controlled affiliates and is typically deferred until the affiliate is sold, or otherwise participates in a group reorganization.
Application of Above Tests (page 10, [paragraph] III.2): The plan states that "[t]he term business component means the most significant set of elements of such product with respect
to which all the requirements [of the Code] are met."
He concluded by requesting a summary of the FTA's position with respect
to the failure to self-assess on the acquisition of real property, where there are no revenue implications discretion may be exercised if there are unusual circumstances.
IT-467R expresses the government's position with respect
to the tax treatment of out-of-court payments to settle disputes where a taxpayer is discharging its own liabilities.
It should be noted here that Sadqa-e-Fitr fixed last year and year before that, with respect
to wheat was Rs 100 also.
461(h)(1) provides that, in determining whether an amount has been incurred with respect
to any item during any tax year, the all events test shall not be treated as met any earlier than when economic performance with respect
to such item occurs.