Since that time, the FSA
has gained regulatory authority over most of the United Kingdom's financial services sectors.
Situation 2: The facts are the same as in Situation 1, except that the FSA
and HRA are limited-purpose arrangements that pay or reimburse, pursuant to the written plan document, only vision and dental expenses (whether or not A satisfies the minimum annual deductible).
The emphasis on notification in the FSA
appears to allow this.
In addition to supporting virtually any storage topology, Eurologic's FSA
architecture provides a cost-effective, "single card" migration path to best-of-breed storage technologies, including emerging intelligent networking technologies that place application intelligence within the storage platform.
The downside of a FSA
is the restrictions imposed by the IRS.
At issue in the FSA
was the character and source of the guarantee fees paid by the taxpayer to the foreign parent, and whether the treaty interest-and-business-profits articles applied to such fees.
Although the FSA
does not constitute authority binding on either the Service or taxpayers, it reflects a potential IRS litigation position.
Clearly, neither a letter ruling nor an FSA
In the FSA
, the taxpayer was a large commercial bank that served as the investment adviser for a family of proprietary mutual funds, including two money market funds that the taxpayer had acquired in a merger with another bank.