Because many foreign jurisdictions now have merger statutes that operate like those of the states, under which all assets and liabilities move by operation of law, the change in the definition of an A reorganization now allows transactions effected pursuant to these statutes to qualify as
statutory mergers or consolidations for Sec.
Even if only a subcomponent of a subcomponent of a finished product constitutes an item, the shrinkback rule will allow a portion of the receipts from the sale of the finished product that includes the subcomponent to qualify as
Any interest in a business other than a bank or domestic building and loan association if more than 35% of its gross income in the year of the decedent's death would qualify as
personal holding company income (dividends, interest, royalties and other investment-type income pursuant to IRC section 543(a)).
Under these circumstances, if J elects to treat debt 1 as not secured by a qualified residence, the interest remains frilly deductible, and all of debt 2 will qualify as
home-equity debt, fully deductible as QRI; see Exhibit 1 on p.
If an activity does not qualify as
research, why should the agent expend the time and effort (and require the taxpayer to expend the time and effort) auditing the precise numbers?
Thereafter, the loan must qualify as
home equity debt or home acquisition debt.
If more than $5,250 of educational assistance is provided to an employee in a program year and the educational assistance is provided for job-related courses, the cost of educational assistance in excess of the $5,250 income exclusion cap may qualify as
The article first reviews the general categories of expenditures that qualify as
"research or experimental" for purposes of both section 174 and section 41.
If a plan covers only the employer's key executives, it should qualify as
a top-hat plan.
However, only the portion of the construction allowance actually expended on qualified long-term real property for use in the lessee's trade or business at the retail space may qualify as
a qualified lessee construction allowance.
To qualify as
an eligible educational institution, the college, university or vocational school, or other postsecondary educational institution, must be an accredited public, nonprofit and proprietary postsecondary institution, and eligible to participate in a Federal financial aid program under Title IV of the Higher Education Act of 1965 (20 USC 1088) (Sec.
Example 2: T previously worked in an accounting firm and did not qualify as
a real estate professional.
Tax advisers should encourage their clients to develop a list of persons and/or entities that commonly qualify as
disqualified persons to avoid engaging unknowingly in a prohibited transaction.
If the qualifying dependent is a married child, this child must qualify as
the taxpayer's dependent under the dependency tests, even though the taxpayer allows the noncustodial parent to claim the dependency exemption only because the taxpayer states in writing that the noncustodial parent may claim the dependency exemption, or the noncustodial parent provides at least $600 support for the dependent and claims the dependency exemption under a pre-1985 divorce decree.
Although option exercises for which the employer does not withhold income taxes would arguably still qualify as
wages under Sec.