The deduction items considered are (1) the target's non-qualified stock options and SARs that vested on the date of a change in control; (2) the target's financial advisory and investment banking fees that were incurred in connection with the acquisition and that became fixed and determinable
on the change in status date; and (3) outstanding target debt that was retired at a premium on the acquisition date but after the closing.
The so-called two-and-a-half-month rule under section 404 only determines whether the bonuses must be treated as deferred compensation; it has no bearing on whether the fact of liability was fixed or the amount was reasonably determinable
as of the end of the prior tax year.
* Not otherwise readily determinable
from the documentation.
According to the report, during August the spam was distributed from at least 25 different countries, with the United States and United Kingdom topping the list of spam producers (together 69.4% of spam issued that was of determinable
By contrast, says PricewaterhouseCoopers, claims that have settled generally involved no contentious coverage issues; direct physical damage whose scope was readily determinable
; relatively short and easily identifiable period of business interruption; low claim amount; and/or loss exceeding policy limits.
The novel centers on a pair of friends in midlife--Sam Grandy, a feckless though happily married man with no determinable
career, and Roy Courtright, heir to a substantial inheritance, who deals in classic cars for upscale clients.
Instead his work is situated within a ramified or networklike thematic field, one that is structured and clearly determinable
. And when certain themes require additional information or discursive precision, he simply extends the visual work into the field of the essay.
Dr Lloyd said: "Whether or not any of the deceased discharged a firearm is not determinable
. In my view as evidence of the event the results are worthless."
The auditor disclaimed an opinion for fiscal year 1998 because the effect of a pending Air Force investigation was not determinable
upon the financial statements.
Lucas: Asset-based lending is financing that is secured by assets of determinable
value, typically trade receivables, inventory or equipment.
Under the Social Security program, the federal government provides Social Security Disability Insurance benefits, or SSDI, to "fully insured" individuals who have contributed to the Social Security program, as evidenced by "work history", and who, because of a medically determinable
physical or mental impairment, are unable to continue performing "substantial gainful work".
Cooper said the value of his first major woodworking project isn't determinable
It focuses on key provisions for recognizing revenue under SAB 101, revenue recognition topics covered in SAB 101, and frequently asked questions related to persuasive evidence of an arrangement, delivery and performance, fixed or determinable
sales prices, and income statement presentation (gross versus net presentation of revenue in the income statement).
While standards of illegality and libelousness are, at least in principle, objectively determinable
in relation to codes of civil and criminal law, obscenity--especially if understood as extending beyond standards laid out by law--is much less so.