In addition to the above two rules, antiabuse
rules were implemented to recharacterize a covered debt instrument as stock if it is issued with the principal purpose of avoiding the application of those rules.
Jackel said it was also noteworthy that the government failed to raise the antiabuse
rule of the regulation that allows the IRS to apply an aggregate approach to partnerships where the IRS determines it is appropriate to do so unless the taxpayer can establish that entity treatment is provided by the statute or regulation at issue and the tax results of entity treatment were clearly contemplated.
ambiguous nature of 'judicial antiabuse
Some of the guidance was developed from an antiabuse
perspective, establishing implicit bright lines through rebuttable presumptions that are difficult to overcome.
rules would prevent tax-motivated sales of assets to governments and nonprofits and tax-motivated conversion of rental housing to owner-occupied use in anticipation of the reform.
In a MANIC on the use of antiabuse
messages, the originator of the MANIC notes the possibility of bigger kids not being able to view the message or having a way to contact authorities.
Marketable securities, however, generally would not include stock (or a partnership interest) issued by a member of the expanded affiliated group that, after the acquisition, includes the foreign acquiring corporation (subject to an antiabuse
25) Alan Gunn, The Use and Misuse of Antiabuse
Rules: Lessons from the Partnership Antiabuse
Regulations, 54 SMU L.
Speaking on background, Vatican officials say that leadership of that commission will be appointed shortly and an initial meeting could take place as early as February It's likely to be housed within the Congregation for the Doctrine of the Faith, the Vatican's powerful doctrinal watchdog agency that since 2001 has also played the lead role in coordinating antiabuse
Subchapter K has antiabuse
rules that generally provide that the provisions of Subchapter K and the regulations thereunder must be applied in a manner that is consistent with the intent of Subchapter K.
Tired as she may have been following an uphill political campaign the last three months, it appears Hontiveros has yet to forget her activist roots that first took her to the streets, including the anticorruption and antiabuse
demonstrations during the Arroyo administration.
Other portions of the discussion draft include a number of antiabuse
rules to prevent erosion of the tax base in the U.