The effect of the trust instrument was to make the trust a collection agent, on behalf of the surviving spouse, with respect
to profit-sharing plan proceeds during her life.
The purpose of the successor rule requires that the reorganization be treated as a deconsolidation event with respect
to P's interest in X.
Although generally reflective of net income concepts, the definition is expressed with respect
to a transaction.
172(b)(3)(C) speaks in terms of "relinquish[ing] the entire carryback period with respect
to a net operating loss." It does not mention either a regular NOL or an AMT NOL.
Further, we question whether such detailed property-by-property reporting is necessary since the disposition of excluded property affects only the surplus accounts and, with respect
to non-excluded property, the reporting requirement duplicates reporting for foreign accrual property income.
Although taxpayers undeniably have the burden of proof (as they do with respect
to all matters reported on their returns), we are concerned by the implication that taxpayers will have difficulty sustaining their burden, even though it is clear that contemporaneous records are not required by the statute and taxpayers have multiple means of documenting their claims.
Once tax has been adjusted pursuant to subsection 232(1) or 232(2), the legislation provides an option with respect
to deciding whether a credit or debit note will be issued.
As an ancillary result of the potential for withholding tax in respect of cross-border payments for "mixed" rights, valuation issues will also become a difficult administrative and compliance problem since taxpayers may be compelled to unbundle the components and value the payment stream with respect
to the separate rights.
Fidya amount needed to be paid for 30 days with respect
to wheat price is Rs 3,000, with respect
to barley, Rs 9,600, with respect
to dates, Rs 48,000 and with respect
to raisins, Rs 48,000 should be paid for 30 days.
Thus, for a taxpayer to currently deduct employment taxes on accrued vacation/bonus pay that is paid in the subsequent year, it must meet the all events test and economic performance must have occurred with respect
to the liability.
Rosenkranz is an authoritative and informative introduction, guide and reference with respect
to an extensive involvement in a congregation consisting significantly of older and aging adults.
2005), The Court of Federal Claims also has ruled in favor of taxpayers with respect
to this issue.