The defendant, Nadeau, pleaded the culpability of nonparties Camus/DEK (the developer) and Webster Bank (Millette's lender) as an affirmative defense for the purpose of apportioning
fault to them under Fabre and F.
The current total number of seats (435) in the House of Representatives of the United States, adopted in 1911, and the method of apportioning
them, adopted in 1929, lead to a larger population variation between the largest and smallest districts of representatives than is possible under an alternative method.
861 regulations in allocating and apportioning
deductions to DPGR.
Nevertheless, the Board balks at apportioning
the credit and insists on a wooden limitation.
For example, assume that in Example 25, X has most of its property and payroll in states B and C, most its sales in state A, and that all three states follow the same three-factor formula method in apportioning
Tax Executives Institute appreciates this opportunity to present its views on the proposed regulations relating to the use of an alternative tax book value method for allocating and apportioning
interest expenses under section 861 of the Internal Revenue Code.
863-3(b)2) provide rules, in the form of examples, for apportioning
The FTC limit is based on foreign-source taxable income, which is the amount after allocating and apportioning
The section 861 regulations were tailored for the purpose of allocating and apportioning
income and expenses between foreign and domestic sources under the foreign tax credit provisions of the Code," the organization stated.
861-9T(g)-(i), a taxpayer may elect to value assets on the basis of tax book value or fair market value (FMV), or on an alternative tax book value method, when allocating and apportioning
The Department's newest position was that more fairly apportioning
a corporate taxpayer's foreign dividend income would eliminate the Commerce Clause discrimination inherent in New Mexico's tax scheme.
954-1(c) provide the basic rules for allocating and apportioning
a controlled foreign corporation's (CFC's) expenses.
The Treasury regulations generally provide three methods for allocating and apportioning
section 863(b) income: the 50/50 method, the independent factory price (IFP) method, and the books-and-records method.
Although some tax advisers question the Constitutionality of a single sales factor in apportioning
a net-worth tax, the courts, to date, have not provided guidance.
Moreover, the IRS itself has recognized the appropriateness of allocating and apportioning
stock losses to the same class of income that a stock gain would have produced, at least in respect of the oil and gas industry.