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Although arguably Technical Advice Memoranda should not be issued where factual agreement does not exist, TEI recognizes that TAMs serve a valuable purpose in the tax compliance process.
CPSC staff issued its 900-page briefing package last October, but the Commission cannot vote on the package or even hold a Commission meeting to discuss options until the third Commissioner is on board.
Due mainly to Inco's determination to upgrade its operations and meet provincial sulphur dioxide emission guidelines, the value of the building permits issued during the first two months of this year was more than five times the value of the permits issued during the same period last year.
Based on the available guidance, if a warrant is issued in consideration for both services and financial risk, the taxpayer should report the entire amount as compensation under Sec.
The list has not been updated publicly since it was issued.
It is worth noting, however, that the promoters of the investment fund may still profit, because they might receive a placement fee at the time of issue and, in some cases, might participate in the agent commission that was received when the business was originally issued.
In addition to staff guidance issued by the PCAOB and SEC in June (Staff Questions and Answers: Auditing Internal Control Over Financial Reporting and Management's Report on Internal Control Over Financial Reporting and Disclosure in Exchange Act Periodic Reports--Frequently Asked Questions, respectively), in a July teleconference sponsored by Glasser Legal Works and RR Donnelly, PCAOB and SEC speakers provided insights on the internal control-related standards (Auditing Standard 2, An Audit of Internal Control Over Financial Reporting Performed in Conjunction with an Audit of Financial Statements and Management's Reports on Internal Control Over Financial Reporting and Certification of Disclosure in Exchange Act Periodic Reports).
It is expected that New Shares issued under the Entitlement Offer to eligible shareholders will be quoted on a deferred settlement basis on June 8 with normal trading for all New Shares issued under the Offer expected to commence as soon as practicable after that date.
In November, the IRS and Treasury Department issued final and temporary regulations providing a simplified procedure for automatically obtaining extensions of time to file certain returns.
In other words, if covered opinions cannot assume that the business purpose of a transaction is to secure tax benefits, and if the only potential profitability expected to arise from a transaction is the tax benefits, then no covered opinion may be issued.
91-10, Accounting for Special Assessments and Tax Increment Financing Entities, discusses whether a property owner should record an obligation for special assessments levied by municipalities or for debt issued by TIFEs.
The Board recently issued a number of important documents in connection with the project and is undertaking several new phases or subprojects this year.
In addition, Fitch assigned recovery ratings (RRs) to all rated securities issued by firms with an IDR of 'B+' or lower.
National Taxpayer Advocate Nina Olson recently issued her 2004 Annual Report to Congress, which raises several key questions about the continuing independence of Appeals.