FBPRFeature-Based Pattern Recognition (image processsing technique)
References in periodicals archive ?
14) The drafters of the regulation recognized this problem and crafted a rule that allows taxpayers with no CFCs at the effective date of the regulations to have as a minimum base an FBPR and U.
Thus, on a taxpayer's 1991 tax return the FBPR and debt-to-asset ratio will be determined by the five-year base period average -- either the immediately preceding five taxable years or the alternative base period -- based on actual historical data.
If a taxpayer elects to apply retroactively the revised netting rule, the 110-percent limitation should apply to the first taxable year that follows the original base-period years and becomes a part of the second tax year's FBPR and debt-to-asset data.