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Disclosure: The tax shelter regulations require corporations to disclose any loss transaction that generates at least $10 million in any single year or $20 million in any combination of tax years (the thresholds are lower for S corporations, partnerships without corporate partners, and individuals); see Regs.
The hedging regulations provide an exception for "inadvertent errors"; see Regs.
28, 2005, and the taxpayer relies on the notice, it will be treated as having timely satisfied the requirements for filing new GRAs, as required by Regs.
Treasury and the IRS are considering whether to issue further guidance under Regs.
Other transactions that should terminate a GILA under Regs.
The notice provides welcome clarification of the GiLA trigger rules in Regs.
If debt issuance costs are de minimis, taxpayers may deduct the costs (1) on a straight-line basis; (2) in proportion to the stated interest payments; or (3) in full at the maturity of the debt instrument; see Regs.
For a variable-rate debt instrument based on the same interest index for the debt's entire term, the debt issuance costs are amortized by treating them as adjusting the yield, which is deter mined based on the index's initial value; see Regs.
Thus, the debt issuance costs would adjust the overall yield based only on the fixed payments under the debt; see Regs.
corporation must report the previously deducted branch loss as taxable income on a DCL triggering event, under Regs.
This basket can have both high- and low-taxed income; see Regs.
has a law that mirrors the DCL rules and disallows the foreign branch loss from offsetting another person's income, Regs.