On behalf of Tax Executives Institute, I am pleased to submit these comments on the proposed regulations under sections 446 and 1221, relating
to the treatment of hedging transactions entered into by members of consolidated groups.
Even though hospital-specific items were being addressed, the HCA opinion provides good insight relating
to the principles underlying cost classification studies.
[sections] 1.162-29(c)(3), if an activity relating
to a lobbying communication is engaged in for a non-lobbying purpose prior to the year preceding the year in which the lobbying communication is made, a presumption is created that the activity is engaged in for all periods for a non-lobbying purpose.
TEI is pleased to have the opportunity to present its views on the draft information circular relating
to the Advance Pricing Agreement procedure and guidelines.
Contemporaneously with the issuance of the proposed section 6662 regulations, the IRS issued temporary and proposed regulations under section 482 of the Code, relating
to intercompany transfer pricing.(1) For simplicity's sake, the proposed section 6662 regulations are referred to as the "proposed penalty regulations" or "proposed regulations" and the proposed and temporary section 482 regulations are referred to as the "substantive section 482 regulations" or the "temporary regulations." Specific provisions are cited as "Prop.
A section 988 transaction may also be subject to the section 446 regulations (relating
to notional principal contracts) which provide a similar mark-to-market election.
I am writing on behalf of Tax Executives Institute concerning two issues relating
to foreign sales corporations (FSCs): (i) the requirement for Joint Committee review of FSC refund claims; and (ii) the effect of the estimated tax provisions on FSCs and their related suppliers.
The ruling provides specifically for deductions in arriving at AGI for expenses incurred by an individual taxpayer in preparing that portion of his return that relates to his business as a sole proprietor, and expenses incurred in resolving asserted tax deficiencies relating
to his business as a sole proprietor.
to property contributions with a tax basis different than FMV) or Regs.
On December 4, 1990, the Internal Revenue Service issued proposed regulations under section 6038A of the Internal Revenue Code, relating
to the information reporting and agency designation requirements for foreign-owned corporations.
corporation (reporting corporation) (1) which is owned at least 25 percent by a foreign shareholder, that shareholder and any related party, especially a foreign related party, directly or indirectly involved in transactions with the reporting corporation, will be required to maintain (and produce and translate when demanded by the IRS) extensive records relating
to such transactions as specified in the regulations.
HB 61 - Relating
to consideration under the public school accountability system of performance on assessment instruments by certain students formerly receiving special education services and to the placement and use of video cameras in certain self-contained classrooms or other settings providing special education services.
The Lands & Real Estate Division at the Municipality of Abu Dhabi City has processed more than 20701 transactions of various types during the first half of this year including commercial, agricultural and residential land plots in addition to villas, hotels, and communal houses as well as other transactions relating
to Property Registration Section.
The Board of Nursing (BON), in response to passage of House Bill 2426, Senate Bill 993 and House Bill 1, adopted amendments to: [section]211.6, pertaining to Committees of the Board; [section]211.7 relating
to the Executive Director; [section]217.2 relating
to Licensure by Examination for Graduates of Nursing Education Programs Within the United States, its Territories, or Possessions; [section]217.4 relating
to Requirements for Initial Licensure by Examination for Nurses Who Graduate from Nursing Education Programs Outside of United States' Jurisdiction; [section]217.5 relating
to Temporary License and Endorsement; [section]217.11 relating
to Standards of Nursing Practice; [section]217.13 relating
to Peer Assistance Programs; and [section]223.1 relating
This scale consisted of items relating
to arranging the homework environment (e.g., "turning off the TV"), managing time (e.g., "setting priorities and planning ahead"), focusing attention (e.g., "starting conversations unrelated to what I'm doing"), monitoring motivation (e.g., "praising myself for good effort"), and controlling emotion (e.g., "cheering myself up and telling myself that I can do it").