Spaces inside the new ship are acoustically and thermally
separate from the old nave: temporal affairs do not compromise the spiritual.
Ships in time
For purposes of the 100%-stock-ownership requirement, Quiggley is disregarded as an entity
separate from Essco; thus, all of Quiggley's assets (including its Zeno stock) are deemed owned by Essco.
Determining eligibility to elect QSub status
The IRS has issued proposed regulations (REG-106681-02) on qualified real estate investment trust (REIT) subsidiaries, qualified subchapter S subsidiaries (QSubs) and single-owner eligible entities disregarded as entities separate from their owners.
Background: Under the Code and regulations, three types of entities may be disregarded as separate from their owners: qualified REIT subsidiaries (under Sec.
Disregarded entities and tax liabilities
subsidiaries were required by local banking laws to maintain minimum capital accounts
separate from that of NatWest, but U.S.
Treaty bars attribution of capital to U.K. bank's U.S. branch
X is a domestic LLC, wholly owned by Y and disregarded as an entity
separate from Y for Federal tax purposes.
Merger of target into acquiring corporation's SMLLC is an A reorganization. (Corporations & Shareholders)
In general, the determination of whether an organization creates an entity
separate from its owners for Federal tax purposes is a matter of Federal tax law, not dependent on whether the arrangement is recognized as an entity under local law (Regs.
Rev. Proc. 2002-22: co-ownership of property or partnership interest?
351 transaction need not be treated as
separate from otherwise identical inventory subsequently acquired or produced in computing cost of goods sold under the dollar-value LIFO inventory method.
Acquisition price establishes base-year cost of bargain inventory
301.7701-3, an eligible entity with only a single owner can elect to be classified as a corporation or it can be disregarded as an entity
separate from its owner (i.e., treated as a tax nothing).
Use of SMLLC to hold real estate of a public charity
A QSub, however, is disregarded as an entity
separate from its S corporation owner, preserving single-entity tax treatment for the QSub and its parent.
Much ado about "nothings"
An entity with only one owner can elect either to be classified as a corporation or disregarded as an entity
separate from its owner (i.e., to be treated as a sole proprietorship, branch or division); certain default rules apply if no election is made.
Don't check the box without first checking SALT ramifications
351 transaction must be treated as a class
separate from nonbargain purchase inventory.
Coordinated Issue Paper released on bargain purchases
A jury found that the paid subscription lists in question had a value
separate from goodwill.
The amortization of purchased intangible assets
Second, the employer must demonstrate that its lines of business are truly
separate from one another.
SLOB regulations finalized
Accordingly, whether the assembled work force is an intangible asset with an ascertainable value and a limited useful life
separate from goodwill or going-concern value is a question of fact.
'Assembled work force' may not be amortized