7) In each of the first two situations, C could be substituted for D, such that P could have the flexibility of distributing all of the proceeds attributable
to the C business of Target (in lieu of the D business) or all the proceeds attributable
to the C business residing in Target and F-Sub (in lieu of the D business of Target and F-Sub).
2003-79 to apply a ratable four-year spread of the share of income attributable
to a change in annual accounting period.
Nonpunitive damages for emotional distress and other nonphysical injuries or sickness to the extent attributable
to a physical injury or sickness.
The regulations specifically prohibit the stacking of penalties, making clear that only one penalty may be imposed even if the underpayment is attributable
to more than one of the accuracy-related penalty components (e.
a) International boycott transactions: Transactions disclosed on Form 5713, International Boycott Report, Schedule A, International Boycott Factor (Section 999(c)(1)); Schedule B, Specifically Attributable
Taxes and Income (Section 999(c)(2)); and Schedule C, Tax Effect of the International Boycott Provisions, must be completed when required by their instructions.
Therefore, TEI recommends that the Subcommittee provide for the abatement of the higher section 6621(c) rate during the period attributable
to a delay by the IRS in considering the taxpayer's administrative appeal of proposed adjustments.
72(t) imposes a 10% additional tax on a taxpayer who receives "any amount" from a qualified retirement plan; the reference to "any amount," and the lack of an exception for amounts attributable
to rollover contributions, indicate that Sec.
Note: If an independent contractor is not used to perform the services or manage the property, the attributable
income is not rent from real property.
Specifically, the proposed regulations (PS-107-88) establish the extent to which certain ratemaking procedures and adjustments that are based on tax savings attributable
to the filing of a consolidated return will be treated as inconsistent with the Code's normalization requirements.
Article 7 of the treaty provides that an entity's business profits are subject to tax only in its state of residence, unless attributable
to a permanent establishment in the other state.