Retailers welcome this safe harbor rule
, which helps to ensure that federal tax policy better reflects the real world realities for retail businesses that undergo store remodels and repairs," said Christine Pollack, RILA vice president for government affairs.
Similarly, for partnerships taxed under foreign law at the entity level, the safe harbor rule
allows a partner to take into account the share of the partnership's foreign tax expenditures proportionate to the partner's share of the income to which those taxes relate when computing U.
In any case where the IRS challenges the employer's use of the transportation-related security rules, it is likely to argue not only that the special safe harbor rule
for security protection in Treas.
We recommend that Treasury devise a bright-line safe harbor rule
that defines clearly what costs qualify for the distribution costs exception to capitalization.
Safe harbor rule
for underpayment of estimated taxes
Concern about field agents' actions also influenced the AICPA's remarks about a possible safe harbor rule
for determining RBIG for inventory.
A similar safe harbor rule
should be adopted to ensure a fair and reliable determination of insolvency under Sec.
Under a de minimis safe harbor rule
, ERGI does not exist in a given year if the related group indebtedness for such year does not exceed (i) the prior year's allowable ERGI; (ii) 10 percent of the average aggregate value of CFC assets; or (iii) the current year's allowable related group indebtedness (RGI).
Increasing this amount to 115% (or anything above 110%) will result in many small businesses and individuals opting out of this safe harbor rule
and having to do much more complicated tax calculations three and four times a year as an alternative.
Grant Thornton recommends that the final regulations contain a general safe harbor rule
eliminating the need for such complexity where the possibility the TIPRA wage limitation will apply is remote.
Even if a safe harbor rule
is established or a fast-track system is put in place, that does not necessarily mean that hospital price gouging will end.
Statements contained in this press release not relating to historical facts are forward-looking statements that are intended to fall with the safe harbor rule
for such statements under the Private Securities Litigation Reform Act of 1995.