In proposing a
bright-line test, HUD is attempting to establish a standard by which anyone can know, merely by learning the facts of a case, whether the compensation is reasonable.
RESPA's latest chapter
The Institute has consistently encouraged the issuance of
bright-line rules to quell the frequent disputes that have arisen since the INDOPCO decision.
Tax Executives Institute--Internal Revenue Service Large and Mid-Size Business Division liaison meeting; February 5, 2002
There is no
bright-line test to determine whether property is held for sale or investment.
Investor vs. dealer status
According to the FSA, the IRS has established a "
bright-line" intent test.
The timing of section 1033 elections: the IRS issues guidance on the nuances of delayed and revoked elections
He noted that the department is also working on ways providing
bright-line guidance on capitalization issues.
TEI carries on; 56th Annual Conference opens in Boston. (Recent Activities)
There are no
bright-line tests to determine whether a charity is involved in prohibited political campaign intervention.
Election-year focus on lobbying and political activities of public charities
Such a
bright-line test could easily ensnare compliant taxpayers, especially given the small (10-percent) threshold for triggering the rules.
Comments on changes in entity classification: special rule for certain foreign eligible entities
The proposed regulations essentially repeat previous guidance, and the court cases do not provide any
bright-line tests for taxpayers to follow.
Internal-use software and the research credit
The
bright-line nexus standard will hopefully help Ohio catch the out-of-state businesses that are selling products or services into the state.
Beware Ohio's CAT
Bright-line rule: Costs incurred in connection with an acquisitive transaction (other than inherently facilitative costs) will not be treated as facilitating the acquisition if incurred on or before the earlier of the date on which:
Final regs. on capitalizing transaction costs
Second, it fails to adequately comply with recent precedent, including Quill's
bright-line "physical presence" test.
An exegesis of the Multistate Tax Commission nexus guideline: the physical presence requirement
51, Consolidated Financial Statements, which established the
bright-line rule of 50% plus one voting interest for determining whether a subsidiary's statements should be consolidated into the parent's.
What constitutes control?
A
bright-line test should be adopted to permit taxpayers to determine whether an intangibles transfer has occurred and, if so, what portion of the transaction should be attributed to that transfer.
Section 482 service regulations