If the disregarded entity has a payment obligation
for more than one partnership liability, the partnership must allocate net value among the partnership's liabilities in a reasonable and consistent manner, taking into account their relative priorities.
University of Connecticut general obligation
bonds (state debt service commitment) 'AA-'.
In Erickson Post, because there was an unconditional obligation
to repay at the time of the agreement, the Tax Court held that the amounts Amoco advanced constituted a loan.
Arnes also had benefited because the transfer relieved him of an obligation
76 billion five-year highway capital spending program is funded 40% with special obligation
bonds and 60% with general obligation
1992), the Fifth Circuit held that the contribution of unencumbered, non-cash property by an employer to its defined benefit retirement plan in satisfaction of its required contribution obligation
was not a prohibited transaction.
Step 6: Calculate estimates of obligation
and expense under present plan and under alternative plan designs being considered.
must be issued by a qualified small issuer;
For example, if I construct or purchase an office building, do I have a closure obligation
that is to be recognized under the proposed statement?
Georgia's nonrefunded bonds are rated "AAA" based on the state's general obligation
to repurchase stock-liability or equity?
Congress "split the baby" heavily in favor of debt in that (1) the applicable obligation
remains a debt instrument for all purposes of the Code, and (2) the portion of the yield that is deemed to be a dividend is treated as such only for purposes of the DRD.