(3) This is an actuarial determination that must be done on a basis no more rapid than a level basis, according to Sec. 419A(c)(2).
Key employees: Another important consideration in evaluating whether and how to provide post-retirement medical benefits is the Sec. 419A(d)(2) rule.
Two cases (4) addressed whether an FPAA was timely filed, and analyzed the interaction between the statute of limitations (SOL) that applies to partnership proceedings under Sec
. 6229 and the general three-year SOL on assessments under Sec
Under the proposed regulations to Sec
. 645, issued Dec.
355, if a corporation (the distributing corporation) distributes to a shareholder with respect to its stock, or to a security holder in exchange for its securities, solely stock or securities of a corporation (the controlled corporation) that it controls immediately before the distribution, no gain or loss is recognized to such shareholder or security holder.
Both IRO Sec
. 1045 and California Revenue and Taxation Code Sec
In achieving reorganization status, a transaction must fit one of the reorganization types (e.g., a statutory merger described in Sec
. 368(a)(1)(A) (an A reorganization)) and meet other requirements in regulations, including continuity of interest (COI), measured at the shareholder level, and continuity of business enterprise (COBE), measured at the corporate level.
In the early 1990s, Treasury issued anti-abuse regulations under Sec
In this case, TLC's per-diem payments were not treated as truck driver wages, so all agree that the Sec
. 274(n) limit did not apply to the drivers.
. 861 regulations provided the drafters of the Sec
Congress recognized this potential inequity and provided relief by enacting Sec
. 66 as part of the Miscellaneous Revenue Act of 1980.
When a taxpayer disposes of an amortizable Sec
. 197 intangible (or a group of such intangibles) in a transaction with an unrelated third party, it must determine whether the intangibles sold are Sec