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 is precedent.
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.
