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Spaces inside the new ship are acoustically and thermally separate from the old nave: temporal affairs do not compromise the spiritual.
For purposes of the 100%-stock-ownership requirement, Quiggley is disregarded as an entity separate from Essco; thus, all of Quiggley's assets (including its Zeno stock) are deemed owned by Essco.
The IRS has issued proposed regulations (REG-106681-02) on qualified real estate investment trust (REIT) subsidiaries, qualified subchapter S subsidiaries (QSubs) and single-owner eligible entities disregarded as entities separate from their owners.
Background: Under the Code and regulations, three types of entities may be disregarded as separate from their owners: qualified REIT subsidiaries (under Sec.
subsidiaries were required by local banking laws to maintain minimum capital accounts separate from that of NatWest, but U.S.
X is a domestic LLC, wholly owned by Y and disregarded as an entity separate from Y for Federal tax purposes.
In general, the determination of whether an organization creates an entity separate from its owners for Federal tax purposes is a matter of Federal tax law, not dependent on whether the arrangement is recognized as an entity under local law (Regs.
351 transaction need not be treated as separate from otherwise identical inventory subsequently acquired or produced in computing cost of goods sold under the dollar-value LIFO inventory method.
301.7701-3, an eligible entity with only a single owner can elect to be classified as a corporation or it can be disregarded as an entity separate from its owner (i.e., treated as a tax nothing).
A QSub, however, is disregarded as an entity separate from its S corporation owner, preserving single-entity tax treatment for the QSub and its parent.
An entity with only one owner can elect either to be classified as a corporation or disregarded as an entity separate from its owner (i.e., to be treated as a sole proprietorship, branch or division); certain default rules apply if no election is made.
351 transaction must be treated as a class separate from nonbargain purchase inventory.
A jury found that the paid subscription lists in question had a value separate from goodwill.
Second, the employer must demonstrate that its lines of business are truly separate from one another.
Accordingly, whether the assembled work force is an intangible asset with an ascertainable value and a limited useful life separate from goodwill or going-concern value is a question of fact.
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