While the proposals adequately addressed these issues in some circumstances, the method for addressing the problem with the excluded
property test (a proposed consolidated income test) created many more problems.
The portion allocable to the personal-use residence is not reported on the return if all the personal-use gain is excluded
The court concluded that based upon that elimination provision, dividends paid out of unitary income of a lower-tier subsidiary should be excluded
from the computation of the amount of Subpart F income included in the water's-edge group.
If a loan is made by a foreign affiliate and the loan is made on capital account, any gain or loss on the repayment or settlement of the loan relating to currency fluctuations between the calculating currency of the affiliate and the currency of the loan will be a gain or loss from excluded
property if the interest on the loan is included in active business income under subparagraph 95(2)(a)(ii).
The Court said a taxpayer must meet two independent requirements before a recovery could be excluded
under section 104(a)(2): (1) the underlying cause of action giving rise to the recovery must be based on tort or tort-type rights and (2) the damages must have been received on account of personal injury or sickness.
However, the reimbursements E makes to employees are not excluded
from gross income under Sec.
When Schleier filed his tax return, he included as gross income the backpay portion of his settlement, but excluded
the portion attributable to liquidated damages.
To address this problem, we recommend that the word "generally" be inserted before the phrase "throughout the year excluded
Tang exercises his power of appointment and eventually transfers all corpus to the children before his death, the corpus will be used up and excluded
from both his taxable and probate estate.
Contract notice: Ensuring the provision of social services to low-threshold facilities for children and young people in socially excluded
localities in the karlovy vary region
Each meets the ownership and use tests and each has a $250,000 excluded
gain and a $20,000 included gain on their individual returns for the year of sale.
Accordingly, executory costs are excluded
from the operating lease amount or the capital lease amount.
Contract notice: Ensuring the provision of social services social services for families with children in socially excluded
localities karlovy vary region.