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References in periodicals archive ?
Arguably, the typical cost-plus contract shifts the benefits and burdens of ownership to the purchasing taxpayer who has the opportunity for gain and the risk of loss. Nevertheless, the dearth of reported cases suggests that the IRS has not disturbed the form of such contracts or characterized the manufacturer as merely the purchaser's agent.
A liability is recourse to the extent that a partner or a related person bears the economic risk of loss for that liability under Regs.
Permitting an employer to limit his losses, while requiring him to retain the risk of loss, seems inconsistent as a policy matter.
A partner's share of recourse liability equals the portion of that liability, if any, for which the partner bears the economic risk of loss (Regs.
Since then, the church bore the risk of loss, had the right to immediate possession, could sue third parties for nuisance or trespass, could erect improvements on the land and--with the couple's consent--could mortgage the property.
The interagency statement calls for banks selling such products on their premises to intensify their disclosure efforts to advise retail customers that the investments are not deposits insured by the FDIC, are not guaranteed by the bank, and are subject to the risk of loss of principal.
1.704-2(b) (4) defines the term "partner nonrecourse debt" as "any partnership liability to the extent the liability is nonrecourse for purposes of [section] 1.1001-2, and a partner or related person (within the meaning of [section] 1.752-4(b)) bears the economic risk of loss under [section] 1.752-2 because, for example, the partner or related person is the creditor or a guarantor." A key issue is how deductions should be allocated that are funded by a general obligation of a limited liability company (LLC) if the obligation is guaranteed by or borrowed from a member and is recourse debt under Sec.
Reinsurance: Insurance that an insurer buys to spread some of its risk of loss on the policies it has underwritten.