James Buslik represented both the tenant and landlord in the transaction
Despite the fact that each of the merger participants is a foreign entity, the transaction
nevertheless could be a statutory merger and thus a "good" type A reorganization under the new regulations, because both Z and Y are qualified participants and the transaction
is not divisive.
13) The California rules require taxpayers to (1) file amended returns, and (2) pay the tax that would have been otherwise due had the taxpayer not participated in the reportable transaction
Drop shipments, multinational contracts and triangulation have long been the staple diet of the transaction
tax specialist, but too often this is focused on the outbound supply chain to the customer, at the expense of in-bound supply chain or manufacturing models.
4) To the extent a taxpayer has reported "financial accounting irregularities" (restatements, for example), the IRS will, subject to its own discretion, request all tax accrual workpapers--even if the listed transaction
Authentication has two aspects: participant verification and transaction
You must obtain the other party's consent to conduct the transaction
by electronic means.
The steps required to perform each type of Transaction
Recovery, and the conditions and potential problems associated with Transaction
Recovery are explained.
She also said the financial reporting standards for such transactions
were limited in scope and needed clarification.
When the counterparties are unsophisticated, either generally or with respect to a particular type of transaction
, the guidance encourages additional steps to ensure that counterparties are made aware of the risks attendant in the specific type of transaction
Kabira Financial Payment Switch (KFPS) is designed to provide the functionality needed to support real-time transaction
acquiring and switching, including message normalization, routing, journal entry, and risk management.
The sale of 310-312 Avenue U in the Sheepshead Bay section of Brooklyn in an all-cash transaction
valued at $1,060,000.
In addition to tax exemption, a benefit of using a nonprofit is perhaps the ability to play down traditional issues over whether a transaction
has a business purpose, as the focus is generally on the generosity of the donation as the reason for the transaction
They also increase the importance of upfront communication between taxpayers and their advisers on whether the transaction
is a RT or the adviser is a MA--and, if so, what disclosure responsibilities and potential penalties flow from such status.
Only one of the "reportable transaction
" categories targets transactions
clearly perceived by the IRS as yielding "too good to be true" tax results--namely, "listed transactions
" specifically identified as abusive tax shelters in published Treasury or IRS notices.