Sec. 1.199-3(a)(1)(ii) and (1).Treasury and the Service recognize that filmmakers' advertising revenue is similar to print media; this revenue can be added to QPAI.
Sec. 1.199-3(j)(2)(i) defines tangible personal property as any tangible property other than land, real property (as described in Regs.
Highlights of the sec. 199 final regs
The proposed regulations address the valuation of stock underlying options and SARs for Sec. 409A purposes.
Actual grants of restricted stock are generally not treated as a deferral of compensation, because such grants-due to the restriction--are not currently includible in income under Sec. 83.
Deferred compensation for executives under sec. 409A
On June 1, 2006, Pension (a qualified trust under
Sec. 401(a)) purchased 18 shares (20%) of Loss Co.
Final Sec. 382 Regs. on distributions from qualified trusts
The
SEC staff is authorized to provide copies of the formal order in response to written requests that specify that the order will be used in connection with the representation of a specific client and will not be disseminated to other individuals or entities.
Responding to an SEC investigation: two attorneys review the dangers posed by an SEC probe, and the ways in which public companies could and should react to minimize the potential damage, including possible litigation
& Tax Code
Sec. 24402(a)--which provides for a dividend-received deduction to the extent that the dividend payor was subject to California corporate income or franchise tax--is unconstitutional because the dividend-received deduction discriminated against interstate commerce, which violates the U.S.
Dividend deductions; Farmer Bros. ruling: Rev. and Tax Code Sec. 24402 unconstitutional
You would be surprised at how many companies communicate with the
SEC in a haphazard manner.
Mind your manners: etiquette can go a long way toward getting results with the SEC
Under
Sec. 6231 (a) (2) (B), the parent would be treated as a partner for TEFRA partnership procedures purposes.
Current developments: this article reviews and analyzes recent rulings and decisions involving partnerships. The discussion covers developments in partnership formation, foreign-source income, debt and income allocations, partnership continuation and basis adjustments
The proposed regulations to
Sec. 645 also provided that a trust that was treated as owned by the decedent under
Sec.
Trust treatment: final regs issued on election to treat revocable trusts as part of estate
Notice 2006-96 provides that an appraiser will be treated as having earned an appraisal designation from a recognized professional appraiser organization under
Sec. 170(f)(11)(E)(ii)(I) if the designation is awarded on the basis of demonstrated competency in valuing the type of property for which the appraisal is performed.
Service issues transition guidance on appraisal requirements for noncash charitable contributions
Due to the tax deferred rollover provisions of IRC
Sec. 1045 (and R&TC
Secs.
Paving the Way
New
Sec. 355(b)(3) is intended to liberalize the active-wade-or-business requirement.
Significant recent developments
In this case, TLC's per-diem payments were not treated as truck driver wages, so all agree that the
Sec. 274(n) limit did not apply to the drivers.
Lessor of truck driver employees avoids 50% limit on per diems
The following intangible assets are covered by
Sec. 197:
The ins and outs of Sec. 197