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First, the taxpayer must be able to establish that he or she has met at least one of the five general requirements outlined in Regs.
In response, for taxpayers that want to use the simplified method of Regs.
overall hedges of interest rate, price or currency risk); see Regs.
Under an anti-abuse rule, the IRS can treat any gains as ordinary, resulting in a potential character "whipsaw"; see Regs.
Substitutes the successor transferred corporation for the original transferred corporation for purposes of Regs.
For purposes of this exception, an "asset reorganization" does not include (1) a triangular asset reorganization described in Regs.
Accordingly, P's allocation relating to its options satisfies the arm's-length standard in Regs.
The partnership agreement should specify the allocation method(s), giving due consideration to the anti-abuse rules in Regs.
The income is excluded by attaching a statement to the income tax return, under Regs.
Because $120,000 is less than de minimis, as determined under Regs.
16) The positive investment adjustment amount is the excess (if any) of the sum of the positive adjustments made to the subsidiary share over the sum of the negative adjustments made to the share under Regs.