Calculating net value: In the preamble to the final regulations, Treasury and the IRS noted that the comments received on a disregarded entity's net value illustrate the difficulty of taking into account
priorities among obligations of disregarded entities in determining their net value, as well as the differing views on the best approach to measure a partner's economic risk of loss.
The Board will consider that the supervision standard has been met where it determines that the applicant bank is subject to a supervisory framework that is consistent with the activities of the proposed representative office, taking into account
the nature of such activities.
At the close of the year, taking into account
the distribution, X's earnings and profits should be (1) decreased by the fair market value of the property distributed ($200) and (2) increased by the liabilities assumed to the extent they do not exceed the property's fair market value.
In analyses taking into account
a woman's number of lifetime sexual partners and her age at first intercourse, HPV-positive women who were also infected with HSV-2 still had nearly twice the odds of squamous cell carcinoma as did those who tested negative for HSV-2 (1.
22, 20(14, but the conferees encourage Treasury and the IRS to expeditiously resolve open cases, taking into account
the AJCA's provisions.
In its friend-of-the-court brief, TEI argued that the Constitution does not permit apportionment of a consolidated or unitary multistate tax base without taking into account
the corresponding apportionment factors of the businesses in the group generating the income or value comprising the tax base.
Fitch's DR ratings, introduced in April 2006 across all sectors of structured finance, are designed to estimate recoveries on a forward-looking basis while taking into account
the time value of money.
481(a) adjustment, taking into account
only those costs incurred in tax years ending after Jan.
If the recapture amount arising from a disposition of property is limited as a result of a disposition by gift or a tax-free exchange, and the transferee subsequently disposes of the property in a transaction that otherwise produces section 467 recapture, the prior understated inclusion for the transferee is computed by taking into account
the amounts attributable to the period of the transferor's ownership.
Taking into account
the changes of the Amsterdam Treaty, new case law of the Court of Justice and recent environmental directives and regulations.
To implement this neutrality policy without adopting new income tax principles requires a reexamination of existing income tax rules, taking into account
their adaptability to technological developments in commerce.
cent requirement in section 351(e) is based on the fair market value of the transferred assets, taking into account
any indebtedness which encumbers such assets.