If the net proceeds of the sale were distributed to the acquired corporation's shareholders immediately before the merger and not retained, the transaction could continue to qualify as
a type A reorganization, because a statutory merger does not have a "substantially all" requirement (as in other types of reorganizations).
Research and experimental activities under section 174 and the creation of intangibles do not qualify as
being substantial in nature for any QPP other than computer software and sound recordings.
Some of the sales might then qualify as
a firm commitment for accounting purposes, which would allow Multico the use of forward contracts.
The general audit plan correctly notes that the legislative history confirms that no formal scientific hypothesis is necessary for a method to qualify as
a process of experimentation.
meets its basic design specifications related to function and performance level" would not qualify as
R&E expenditures under section 174 unless they were made to cure a significant design defect, obtain significant cost reductions, or achieve significantly enhanced function or performance levels.
Since loan amounts may exceed the limit after October 13, 1987, only a portion may be grandfathered; the excess may qualify as
home equity debt.
If more than $5,250 of educational assistance is provided to an employee in a program year and the educational assistance is provided for job-related courses, the cost of educational assistance in excess of the $5,250 income exclusion cap may qualify as
If a plan covers only the employer's key executives, it should qualify as
a top-hat plan.
TEI believes that all research activities up until the time the product is ready for commercial sale should qualify as
R&E for purposes of section 174.
Events that qualify as
a disaster are usually of a mass proportion (e.
To achieve these benefits, the foundation must qualify as
a passthrough foundation for a particular tax year by:
However, only the portion of the construction allowance actually spent on qualified long-term real property may qualify as
a qualified lessee construction allowance.
190 permits a taxpayer to currently deduct the costs of improvements that qualify as
architectural and transportation barrier removal expenses, in the tax year paid or incurred.
To qualify as
an eligible educational institution, the college, university or vocational school, or other postsecondary educational institution, must be an accredited public, nonprofit and proprietary postsecondary institution, and eligible to participate in a Federal financial aid program under Title IV of the Higher Education Act of 1965 (20 USC 1088) (Sec.
Example 2: T previously worked in an accounting firm and did not qualify as
a real estate professional.