Agree on the roles of the individuals and the brand names that will be used--never
agree to agree later.
Two-stage deals: a sequenced transition can smooth a firm's ownership transfer
[section] 846, simply provides that those who conspire to violate the federal drug laws are to be punished to the same degree as they could be for the drug crime they
agree to commit.
Drug conspiracies
We have occasionally discovered technical issues relating to how the tax on the return is computed while trying to
agree to the computation on the RAR.
Streamlining the audit process responses of TEI members to LMSB survey questions: May 24, 2002
The agreement period may last anywhere from one to three years, and may be renewed if both parties
agree to do so.
Managing sales and use tax compliance and administration with self-audits and managed compliance agreements
The buyer, however, would not
agree to the changes until it received a letter directly from the Patterson Town Board stating that the subdivision would not be affected by the new zoning ordinance.
Brokerage commissions must be earned
Many of these issues can now be resolved via a cost-sharing agreement under which the related parties can, in advance,
agree to share the development costs commensurate with the benefits to be derived.
DHL - international transfer pricing wake-u call
* Provide standardized procedures to which the taxpayer and the IRS could
agree to implement into the audit process starting with the initial contact and ending at the post examination critique and to resolve all issues at the lowest possible level.
Involving the taxpayer in the audit planning process: a cooperative effort of the Cincinnati and Cleveland Chapters of the Tax Executives Institute and the Ohio District of the Internal Revenue Service
Perhaps in an attempt to obtain financing in the first place, or to convince a real estate lender to extend more credit than it believes a particular construction project on completion will justify, or to salvage a troubled project, developers will often
agree to guaranty interest payments to lenders.
Post-maturity effect of interest guaranties
For example, under the alternative-timing resolution, the Service and the taxpayer may
agree to capitalize certain costs incurred only for the period under examination.
IRS-initiated accounting method changes
In September 1995, the National Office issued final procedures for Appeals mediations, stating that the test period would begin on October 30, [1995..sup.4] In mid-October, the Chief Counsel's procedures accepting mediation in docketed Tax Court cases became [public..sup.5] At this point, only the Justice Department's Tax Division refuses to
agree to mediation in refund or other tax cases.
Tax Court mediation: a case study
The IRS reserves the right to require specifically that an eligible QI
agree to include certain of its branches (to ensure the disclosure of certain U.S.
Qualified intermediary application process contains a number of surprises
In some cases third parties may also
agree to compensate an entity based on actual costs or results or to renegotiate or reset prices, even retroactively, if significant changes occur.
OECD draft transfer pricing guidelines
Section 1 of the proposed procedure provides that both the taxpayer and Appeals must
agree to mediate.
Announcement 95-2: Appeals mediation
Each party has present at the mediation someone with authority to
agree to a final settlement of the case for that party-a crucial aspect of a successful mediation procedure.
Mediation under Announcement 95-2: IRS proposes dramatic extension of alternative dispute resolution
At the inception of an examination the IRS and taxpayer will have their best opportunity to
agree to joint objectives including involving the taxpayer in planning the examination, identifying the proper resources (in terms of personnel, tools, and facilities), establishing joint examination objectives, exchanging fundamental information, and committing mutually to resolving substantive issues at the lowest possible level.
Improving the audit process: a cooperative venture