If consumers are already seeking variety in a product class, the optimal strategy for a brand would be to
satisfy the consumers' desire for variety--but at the same time to encourage as much brand loyalty as possible.
Although the final COI regulations provide for a 40% COI safe harbor, the regulations do not specify a minimum level of propriety interest that must be issued to
satisfy the COI requirement.
The requirement that tax benefits must
satisfy, in effect, a "should-prevail" level of confidence for initial recognition of tax benefits will systematically overstate tax expense and tax liabilities (or understate tax assets) in certain periods and create gains in subsequent periods when the statute of limitations expires (or an examination is concluded and the matter resolved).
* MEMBERS SHOULD
SATISFY THEMSELVES regarding the competence, practices and procedures of any third-party provider, regardless of the type of services provided or the location at which they are performed.
Rather, they attempt to minimally
satisfy the needs of marginal stakeholders and maximally
satisfy the needs of their key stakeholders.
170(h), because the attempted grant did not
satisfy the Sec.
In assisting the taxpayer in tax planning, the member should inform the taxpayer of the penalty risks associated with the tax return position recommended with respect to any plan under consideration that satisfies the realistic possibility of success standard, but does not possess sufficient authority to
satisfy the more likely than not standard.
In addition, this ruling provides guidance on what constitutes a reasonable interest rate to determine payments which
satisfy the substantially equal periodic payment requirement.
All employer matching contributions and nonelective contributions that are used to
satisfy the safe harbor rules must be nonforfeitable and subject to the restrictions on withdrawals and distributions that apply to an employee's elective deferrals under a 401(k) plan.(2) Since all such contributions must be fully vested when made, an employer that utilizes the safe harbors will generally be unable to reduce future employer contributions through the use of forfeitures.
* A foreign trust is any trust that fails to
satisfy the court or control test for establishment of U.S.
* IN UNITED STATIONERS, THE DISTRICT COURT SAID the taxpayer did not qualify for the research credit because its software development activities did not
satisfy the discovery and process of experimentation requirements.
According to the Service, these transactions should be treated as reorganizations if they
satisfy the functional criteria applicable to transactions under domestic statutes.
In support of its rule 12(b)(6) motion, the firm successfully asserted that the general allegations of GAAP and GAAS violations failed to
satisfy the scienter requirements of section 10 (b) and rule 10b-5.
[section] 1.414(r)-11(b)(7) defines the "first testing day as the earliest day in the testing year on which any plan of the employer is required to
satisfy section 410(b).
411 (a)(7), all amounts credited to a participant's account under the plan are part of the accrued benefit and must
satisfy Sec.