Thus, the definition of statutory mergers or consolidations allowed transactions
effected pursuant to the statutes of foreign jurisdictions or U.
Tax shelters that are determined by the IRS to be abusive tax avoidance transactions
are identified as "listed transactions
In contrast, ERPs provide only basic transaction
tax functionality to calculate tax on sales and purchase transactions
, and some reporting options focused around basic compliance functionality
For purposes of this Interpretation, tax planning includes, both with respect to prospective and completed transactions
, recommending or expressing an opinion (whether written or oral) on (a) a tax return position or (b) a specific tax plan developed by the member, the taxpayer, or a third party.
3) If a return involves multiple listed transactions
, then the Service will, subject to its own discretion, request all tax accrual workpapers.
A discussion of legal issues in documenting e-commerce transactions
begins with basic questions, such as what constitutes adequate business records of an e-commerce transactions
The following is a primer on how to apply the California Electronic Transactions
Recovery is an application recovery whereby the effects of specific transactions
during a specified timeframe are removed from the database.
In the remainder of my testimony today, I would like to focus on one aspect of the market for financial transactions
that has drawn considerable attention in the wake of recent losses--the relationship between dealers in financial markets and their customers.
The card industry is confronted with explosive growth in the volume of transactions
while the average revenue per transaction
is rapidly declining - from $1.
To effect these transactions
, shelter promoters in the for-profit sector are moving over to tax-exempt organizations to serve as "accommodating parties.
The new rules are generally effective for transactions
reportable in returns due after the date of enactment (October 22, 2004).