RESOLVED: That the AICPA management consulting services executive committee is hereby designated to promulgate standards under rules 201 and 202 with respect to
the offering of management consulting services, provided, however, that such standards do not deal with the broad question of what, if any, services should be proscribed.
Those participants in a nonqualified deferred compensation plan with respect to
whom there is a failure to satisfy the election and distribution requirements will be taxed currently on their deferred amounts under the plan.
Thus the original difference between individuals who are psychiatrically disabled and individuals who ar physically disabled in percent change with respect to
number of applicants - approximately 14% - increases to 17% with respect to
number rehabilitated and increases again to 23% with respect to
number competitively employed (Figure 9).
17A) Under another recent revenue procedure, corporations required to file the new Schedule M-3--"Net Income (Loss) Reconciliation for Corporations with Total Assets of $10 Million or More"--will be deemed to have satisfied the disclosure requirement of the RT regulations with respect to
more than $10 million book-tax differences if the M-3 is completed in accordance with its instructions and is timely filed with the original return.
The average scores with respect to
this category across the four submissions were 2.
With respect to
banking in the United States, this provision relates primarily to cross-border lending and deposit-taking.
If a contract is "benefit responsive," the plan does not receive "passthrough" or any other coverage with respect to
With respect to
the first exception, the court noted that a co-holder of a discretionary power to distribute trust assets, such as a bank, has no adverse interest merely because of its joint possession of the power.
Although tax executives should consider the potential application of the FIE Rules to any direct or indirect equity investment by a Canadian taxpayer in an NRE, particular care should be taken with respect to
the tracking interest rules.
Therefore, income or loss with respect to
such loans will not be included in FAPI but will affect the affiliate's surplus balances (and will not be deemed to be nil under paragraph 95(2)(g)).
The changes also expand the foreign reporting rules with respect to
transactions between Canadians and non-residents, primarily to ensure that transactions involving partnerships and their members fall comprehensively within the ambit of these rules.