Disclosure: The tax shelter regulations require corporations to disclose any loss transaction that generates at least $10 million in any single year or $20 million in any combination of tax years (the thresholds are lower for S corporations, partnerships without corporate partners, and individuals); see Regs.
The hedging regulations provide an exception for "inadvertent errors"; see Regs.
28, 2005, and the taxpayer relies on the notice, it will be treated as having timely satisfied the requirements for filing new GRAs, as required by Regs.
Treasury and the IRS are considering whether to issue further guidance under Regs.
Other transactions that should terminate a GILA under Regs.
To the extent that the sum of debt issuance costs and any OID on the debt does not exceed the de minimis OID threshold, Regs.
If debt issuance costs are de minimis, taxpayers may deduct the costs (1) on a straight-line basis; (2) in proportion to the stated interest payments; or (3) in full at the maturity of the debt instrument; see Regs.
For a variable-rate debt instrument based on the same interest index for the debt's entire term, the debt issuance costs are amortized by treating them as adjusting the yield, which is deter mined based on the index's initial value; see Regs.
corporation must report the previously deducted branch loss as taxable income on a DCL triggering event, under Regs.
This basket can have both high- and low-taxed income; see Regs.
In the third situation, X owned all of the membership interests in limited liability company LLC, an eligible entity that elected under Regs.
355 did not apply, it did not constitute tax avoidance, because it was motivated by a bona fide business purpose within the meaning of Regs.