Subject to certain restrictions and limits, Sec
. 965 generally permits a corporation that is a U.S.
Such an arrangement does not meet the Sec
. 125(d)(2) cafeteria plan rules that prohibit salary reduction amounts from being used to purchase deferred benefits.
* Many rulings were issued on TEFRA audits, taxation of partnership income, Sec
. 704(b), partnership conversions, basis adjustments and in other areas.
For example, the definition of a trust qualifying to make the Sec
. 645 election is expanded.
The Service issued temporary regulations amending regulations under Secs
. 302, 331,332, 338, 351,355, 368, 381,382, 1081, 1221, 1502, 1563 and 6012.
Due to the tax deferred rollover provisions of IRC Sec
. 1045 (and R&TC Secs
* Other final regulations address COI satisfaction when the issuing stock declines in value after the sing date, the interpretation of plans under Sec
. 355(e) and loss disallowance on a sale of subsidiary stock.
The tax matters partner argued that the GP had no SE earnings as defined in Sec
. 1402(c), because neither the partnership nor any of its partners had an individual as an owner.
The undisputed facts demonstrate that TLC, as taxpayer, paid per-diem expenses to the truck drivers and provided its trucking company clients with the expense substantiation information required by Sec
income tax return that includes the Sec
. 199 deduction introduced by the American Jobs Creation Act of 2004 (AJCA).
* Under Sec
. 66(b), a spouse may be disallowed the benefits of reporting
When a taxpayer disposes of an amortizable Sec
. 197 intangible, recapture rules may require treating any resulting gain as ordinary income.