When both amounts are positive, and DEI is greater than DTIR, subject to the taxable income limitation of Sec.
A domestic corporation is treated as owning specified tangible property that it transfers to a "specified related party" if (1) the corporation transfers the property with a principal purpose of decreasing its DTIR, and (2) the domestic corporation or an FDII-eligible related party (i.e., a member of the same domestic consolidated group or a partnership at least 80% of which is owned by members of the consolidated group) leases the same or substantially similar property back during the "disqualified period." The disqualified period is the period beginning one year before the transfer and ending the earlier of (1) the end of the remaining recovery period of the property or (2) one year after the date of the transfer.
A transfer or lease to an unrelated party would be treated as made to a specified related party if done under a "structured arrangement." A structured arrangement will exist if (1) the reduction to the domestic corporation's DTIR is a material factor in pricing the transfer or lease, or (2) a principal purpose of the arrangement (applying a facts-and-circumstances test) is the reduction in the domestic corporation's DTIR.
A transfer of property to a specified related party (or a party deemed to be a specified related party), followed by a leaseback of the same or substantially similar property within six months of the transfer, would be treated as per se having a principal purpose of decreasing the domestic corporation's DTIR.
250 deduction by referencing the relevant items of all members of a consolidated group, aggregating each member's DEI, FDDEI, and DTIR, and also aggregating each member's GILTI inclusions (and associated Sec.
Using the shared-supervision model for clinical practice and the DTIR
Program as navigational tools for increased collaboration and dialogue between the university and its associated schools and districts, the transformation of public education via collaboration and partnerships moves one step closer to becoming the reality of the educational climate in San Diego County.
The measure of dSIR can be based on the same scheme used for dTIR, fixing an absolute level of SIR through the same time dependences computed only for the systematic part of the risk for the average rt.
for the Dow Jones Eurostoxx 50) to measure proxies of IR at total level (dTIR) and also to split the systematic (dSIR) and the idiosyncratic (dDIR) components for the main industries-index composing the market-index.
dTIR = [TIR.sub.t] - [TIR.sub.t-1] [congruent to] [partial derivative]TIR/[partial derivative]t 1<t<4760 (9*)
The time series for Total IR contains 4,759 observations, being the first dTIR data computed on January 3, 1992 (i.e.
The computation of dSIR is similar to that of dTIR.
Being the gaps enough uncorrelated and widespread, we examine their possible relationship with the TIR, its components (SIR and DIR) and their time-changes (dTIR, dSIR, dDIR).