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In this case, his tax adviser should advise him to initiate these efforts during the 1996 tax year for this debt and any other account receivable that Jack feels may be uncollectible.
F-1 [the surviving company] will be the successor in interest to F-2 with respect to any account receivable established in accordance with section 4.02 of Rev.
Recharacterization of any transaction-year distributions as nontaxable is clearly allowable (including various multi-tier situations The ability to avoid a dividend by establishing an account receivable is not explicitly discussed in the revenue procedure, but there is no apparent theoretical or policy bar to relief.(31) The tax costs of imputed interest on such a receivable must be considered, absent waiver in a competent authority proceeding.
The court found sales made by Toys R Us through its retail outlets in the state created an account receivable and Geoffrey's licensing agreement with the company resulted the creation of a franchise.
M2 EQUITYBITES-May 19, 2014-Sprint enters into account receivables securitisation agreement