. 1.199-3(g)(3), the in-whole-or-in-significant-part requirement is met if the taxpayer's direct labor and overhead related to a QPP item accounts for 20% or more of its COGS or, in a transaction without COGS (e.g., a lease, rental or license), direct labor and overhead account for 20% or more of the QPP's unadjusted basis.
NQSOs may escape characterization as deferral of compensation under Sec
. 409A if, under the plan:
. 1.382-10(a) (1) applies to distributions from qualified trusts under Sec
Because the initial response to an SEC
investigation is crucial, a corporation that receives an SEC
voluntary information request or a subpoena should immediately attempt to determine the following:
. 24344(c), the foreign investment interest offset, will not be applicable in most cases for tax years ending prior to Dec.
Obligation may not be a private activity bond (other than a qualified Sec
. 501(c)(3) bond, as defined in Sec
By sharing everything, you increase your credibility with SEC
The owners requested a ruling that the property's ownership did not create a partnership, so that they could determine whether the property qualified as replacement property under Sec
The regs state that a QRT is a trust that is treated as owned by the decedent under Sec
. 676 by reason of a power that was exercisable by the decedent only with the consent or approval of a nonadverse party or only with the approval or consent of the decedent's spouse.
Under new Sec
. 6695A, if the claimed value of property based on an appraisal results in a substantial or gross valuation misstatement under Sec
The portion of the gain excluded under Sec
. 1202 from capital gains taxation must be included on federal Form 6251, Line 14m, and on California Schedule P, Line 131.
. 355(b)(2)(A), a corporation is treated as engaged in the active conduct of a trade or business only if it is directly engaged in the active conduct of a trade or business, or "substantially all" (2) of its assets consist of stock and securities of a corporation controlled by it that is so engaged.