Anti-abuse rules: The FDII proposed regulations include antiabuse
rules for transfers of specified tangible property to related parties and certain unrelated parties.
(106) The recently proposed GILTI regulations include two antiabuse
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.
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.
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.S., available foreign tax credits to stop double taxation of non-exempt foreign income and all pre-effective date, tax-deferred income foreign earnings of foreign companies (owned by 10 percent of U.S.