The sine qua non of the unitary business principle is the elimination of artificial line-drawing between entities engaged in the same general enterprise, which inures
to the benefit of taxpayers and tax administrators alike.
338, or was a taxable asset purchase, no tax attributes would inure
to the parent and no PII tax, built-in gains tax, etc., would apply.
Even though the broker was not party to the contacts of sale, the Court ruled that the contact clauses made specific reference the broker's representations, and thus, these barring provisions of the contract inure
to the broker's benefit.
The arrangement between H and L allows a portion of those revenues to inure
Also, the disintegration of communism in Europe will have an enormous impact on private sector expansion in business, which, of course, will inure
to the benefit of New York since all of these countries will be represented here in many different industries.
One type of benefit sought to be obtained from grantor trust treatment - exemplified by the "defective-trust" - is the payment of income tax by the donor on income that will inure
to the benefit of other family members (such as children), who are remaindermen of the trust.
The IRS also determined that arrangement did not cause any earnings or benefits to inure
to private parties.
In the first case, the Service reasoned that the dividend restriction on the issuer's stock was not a real penalty within the meaning of the regulations because it did not inure
directly to the holder's benefit.
By using a GRAT to transfer appreciating property to a younger generation, a family can increase its overall net worth, by reducing the gift and estate taxes associated with the transfer and shifting, during the trust's term, the income tax burden to senior family members while the benefits inure
to the benefit of the junior family members.
The injury that would inure
to the relationship by the disclosure of the communications must be greater than the benefit thereby gained for the correct disposal of litigation.