The establishment of the same
rule for the appointment of taxes, will probably be as little contested; though the rule itself in this case, is by no means founded on the same principle.
Federalist Papers Authored by James Madison
To avoid, therefore, all imputation of laying down a
rule for posterity, founded only on the authority of ipse dixit --for which, to say the truth, we have not the profoundest veneration--we shall here waive the privilege above contended for, and proceed to lay before the reader the reasons which have induced us to intersperse these several digressive essays in the course of this work.
The History of Tom Jones a Foundling
Treasury implicitly acknowledged its authority to adopt a de minimis
rule for the acquisition costs of tangible property, as well as the potential benefits of such a rule, in Rev.
An overview of the proposed "tangibles" regulations
Accordingly, in the example above, to change to an accounting method under which X could deduct in 2005 the insurance premium and equipment rental payments attributable to 2006, X would have to file two Forms 3115--one under the automatic consent procedure by the due date of the 2005 return to change to the 12-month
rule for both payments, and the other under the advance consent procedure, which would have to be filed by Dec.
Sec. 263(a) 12-month rule and economic performance accounting method changes
To ensure the availability of the
rule for subsequent resales by initial investors, the issuing company must provide to proposed secondary market purchasers, on request, certain narrative and financial disclosure about itself (essentially, a very brief description of its business and its most recent financial statements, which may be statutory-basis rather than based on generally accepted accounting principles, or GAAP).
The winding road to reward: Rule 144A securities offerings can be a good source of capital for mutual insurance companies, but getting there requires effort
The adviser had to maintain records of the information required under the
rule for SEC examination.
Investment adviser advertising: for the uninitiated, the SEC's complex rules can have unintended consequences
EPA promulgated the final
rule for secondary aluminum maximum achievable control technology (MACT) requirements in March 2000, following an extended period of emission testing and regulatory development with the Aluminum Association and its members.
Breathing room: companies melting aluminum scrap need to check whether they need to be in compliance with new EPA rules
Most of the business groups are challenging the
rule for the following reasons: the science supporting ergonomics is inadequate, the standard is ambiguous and is based on flawed economic anal ysis, and OSHA did not follow proper procedures in developing and issuing the rule.
Battle Over Ergonomics Moves to the Courts
The Court found support in Leon for "a categorical exception to the exclusionary
rule for clerical errors of court employees"(15) because:
"Good faith": police reliance on computerized information
For hybrid entities, the entity's books and records control; unlike the
rule for branches, interest expense of the domestic owner is not attributed to the hybrid owner.
TEI comments on dual consolidated loss rules: August 22, 2005
The proposed regulations (other than the anti-avoidance
rule for reimporting a loss) would apply to transactions occurring after March 6, 2002, if they occur during a tax year for which the original return is due after temporary or final regulations are published in the Federal Register.
IRS issues proposed anti-loss-duplication consolidated regs
CSC was entitled to follow the old
rule for one more year.
Retroactive revenue rulings
EPA currently is developing a
rule for the major sources of HAPs (facilities with more than 10 tons/yr of any individual HAP or more than 25 tons/yr of total HAPs).
Metalcasters Take the Issues to Capitol Hill
Interestingly, the IRS continues to reject the validity of a 12-month
rule for years before the effective date of the final regulations and has begun denying pending requests to change to a method of accounting using a 12-month rule where the changes were filed for prior years under the authority of U.S.
The final INDOPCO regulations: a primer
The purpose of the seven-day rule in the regulations was to exclude short-term rentals (such as videotapes, cars and hotels), but several court cases (e.g., Barniskis, TC Memo 1999-258, and Toups, TC Memo 1993-359) have upheld the seven-day
rule for vacation homes.
Vacation home tax planning: shaky foundations not easily repaired with software