Specific identification rules are provided for identifying the hedged item when the taxpayer is hedging inventory, debt, assets that have not yet been acquired, and aggregate risk (i.e., overall hedges of interest rate, price or currency risk); see
Regs. Sec.
Hedge identification and timing rules - traps for the unwary
parent enters into a new GILA (for the remainder of the original five-year term), in which it agrees to recognize the gain in accordance with
Regs. Sec.
Effect of certain asset reorgs. on gain recognition agreements
Accordingly, P's allocation relating to its options satisfies the arm's-length standard in
Regs. Sec.
Allocation of employee stock options to cost-sharing agreement
If debt issuance costs are de minimis, taxpayers may deduct the costs (1) on a straight-line basis; (2) in proportion to the stated interest payments; or (3) in full at the maturity of the debt instrument; see
Regs. Sec.
Capitalizing and amortizing debt issuance costs
(13) If a foreign country (e.g., the U.K.) has a law that mirrors the DCL rules and disallows the foreign branch loss from offsetting another person's income,
Regs. Sec.
Forms of overseas operations: this two-part article explores the major characteristics, advantages and disadvantages of the different types of entities for conducting business overseas
355 did not apply, it did not constitute tax avoidance, because it was motivated by a bona fide business purpose within the meaning of
Regs. Sec.
Significant recent developments
It then reviewed the relevant cases, the amendment of
Regs. Sec.
TC upholds GSTT Regs
Waiver's Scope: Under this initiative, the IRS will waive the filing deadlines set forth in
Regs. Secs.
Recent developments: truck and van depreciation, automatic extensions and more
475(f) election and a letter explaining why he should be entitled to an extension under
Regs. Sec.
TC clarifies filing requirements for mark-to-market election
Reg. [sections] 1.1502-13(e)(1), a special rule is provided for the situation in which S sells inventory to B and either member uses dollar-value LIFO to account for intercompany transactions.
Consolidated return intercompany transaction regulations: clearly reflecting income is clearly not simple
Stewardship expenses: The temporary regulations modify
Regs. Sec.
Controlled services transactions
Purchases are taken into account in computing the cost of goods sold, which is an offset, or exclusion, employed in the computation of gross profit and gross income (section 1.61-3(a), Income Tax,
Regs.); whereas, throughout the Code, the term "deduction" is used to refer to amounts subtracted from gross income to arrive at taxable income.
Proposed regulations concerning the economic performance requirement under Section 461(h) of the Internal Revenue Code
shareholder owns 5% or more of either PLC's vote or value, such shareholder must enter into a five-year gain recognition agreement (GILA) relating to USHoldco shares; see
Regs. Sec.
U.S. companies take "AIM" at the U.K. stock market
Regs. [sec.] 1.861-10T(d)(2) and [sec.] 1.861-9T(g)(2)(iii).
Allocating interest and other expenses under Section 864(e)
The final regulations clarify the application of these rules to subcontractors as well; see
Regs. Sec.
Highlights of the sec. 199 final regs