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47) The federal income tax is similarly--and necessarily--already interacting with state and local tax and borrowing decisions, and so the Code is in a position to nudge states and localities to more stable tax systems ex ante, obviating in part the need for federal interventions ex post.
Members of the clergy always are self-employed for Social Security purposes even if they are treated as employees for federal income tax purposes.
The disregarded entity takes ownership of the assets of which its parent is treated as owning for Federal income tax purposes; and
HB 130, Laws 2005, provides that effective for tax periods beginning after 2004, unincorporated organizations that elect out of partnership treatment for Federal income tax purposes are considered to have elected out of partnership treatment for Louisiana corporation income tax purposes.
Helvering (35-1 USTC [paragraph] 9043), 293 US 465,469 (1935), argued the $129,000 of compensation John returned to JMA was excludible from gross income because the couple was entitled to structure their transactions to pay the least amount of federal income tax.
Caveat: Individuals who decide not to put any of the money back because they now need to live on it as a result of Hurricane Katrina, will pay Federal income tax and possibly a 10% penalty when they file their 2005 income tax returns.
On behalf of Tax Executive Institute, I am pleased to submit these comments on the Internal Revenue Service's proposed regulations on the application of the normalization requirements of sections 167(l) and 168(i)(9) of the Internal Revenue Code to utility companies that file consolidated federal income tax returns.
If taxpayers or their businesses received insurance proceeds to replace property destroyed by Hurricane Katrina, KETRA Section 405 gives them a longer time in which to invest them in replacement property before incurring Federal income tax liability on any gain; see also "Caveat" below.
The principal tax benefit associated with adopting a subsidiary structure is the ability of a company, on federal income tax returns, to offset profits in one part of the business with losses in another.
Interest on all types of Treasury securities is taxable on federal income tax returns.
Except as set forth in the Disclosure Schedule, neither Company nor the Subsidiaries is subject to any joint venture, partnership, or other arrangement or contract which is treated as a partnership for federal income tax purposes.
First, the Offer raises certain questions about its potential impact on Patriot's tax status for federal income tax purposes.

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