The company also sought a private ruling
from the Commissioner for Domestic Taxes regarding the status of the project and by another private ruling
, KRA held that the project is zero rated.Based on the advice given, the company said it made an application to KRA seeking a refund of Sh166 million but instead received a letter on May 23, 2018 where KRA disallowed the application for a refund.
It has been argued that the private ruling
system developed into a body of law known only to a few members of the tax profession.
However, you might want to check with one of the home schooling associations that may have secured a private ruling
on that issue.
The mantra of the past decade has been, "Why lend for a certain loss when you can buy government paper for a small but certain profit?" So wouldn't dramatic yen depreciation collapse the long-term government debt market and all but force the temporary nationalization of the banking system, if not the collapse of the current public and private ruling
In a private ruling
, it was held that such a provision is not a substantial restriction on the trustee's discretion.(9)
The preamble to the Proposed Regulations provides that the rules were issued in response to the increased number of private ruling
requests involving application of section 7704(d)(1)(E), as opposed to a change in policy or other concerns regarding these entities.
In the fourth private ruling
, the decedent owned two IRAs, both payable to a trust.
There has even been a private ruling
allowing a combination of new construction, renovation and commercial space to qualify for three different targeted incentive programs.
Such a dealer is not eligible to identify its NPCs and derivatives as held for investment, unless the commissioner explicitly determines otherwise, for example, through a revenue ruling or private ruling
. Because it represents a substantial departure from the previous regulations, the rule only applies to NPCs and derivatives acquired or entered into on or after January 23, 1997.
In a recent private ruling
, the IRS clarified that an entity may be subject to one adverse definition but not the other (TAM 9324001).
In a private ruling
that will affect CPAs in public practice as well as their clients, the IRS acknowledged a partner in a professional firm could deduct auto, travel and meal expenses on form 1040 if the partnership policy requires the expenses to be incurred personally without reimbursement (technical advice memorandum 9316003).
355/D reorganization transaction based on the relative FMVs of the distributing and controlled corporations is a standard representation that the Service requires in private ruling