In proposing a bright-line
test, HUD is attempting to establish a standard by which anyone can know, merely by learning the facts of a case, whether the compensation is reasonable.
The Institute has consistently encouraged the issuance of bright-line
rules to quell the frequent disputes that have arisen since the INDOPCO decision.
There is no bright-line
test to determine whether property is held for sale or investment.
According to the FSA, the IRS has established a "bright-line
" intent test.
He noted that the department is also working on ways providing bright-line
guidance on capitalization issues.
There are no bright-line
tests to determine whether a charity is involved in prohibited political campaign intervention.
Such a bright-line
test could easily ensnare compliant taxpayers, especially given the small (10-percent) threshold for triggering the rules.
The proposed regulations essentially repeat previous guidance, and the court cases do not provide any bright-line
tests for taxpayers to follow.
nexus standard will hopefully help Ohio catch the out-of-state businesses that are selling products or services into the state.
rule: Costs incurred in connection with an acquisitive transaction (other than inherently facilitative costs) will not be treated as facilitating the acquisition if incurred on or before the earlier of the date on which:
Second, it fails to adequately comply with recent precedent, including Quill's bright-line
"physical presence" test.
51, Consolidated Financial Statements, which established the bright-line
rule of 50% plus one voting interest for determining whether a subsidiary's statements should be consolidated into the parent's.
test should be adopted to permit taxpayers to determine whether an intangibles transfer has occurred and, if so, what portion of the transaction should be attributed to that transfer.