Distributions are subject to re-characterization
for tax purposes after the end of the fiscal year.
5) Six months after the closing arguments, the Trial Chamber determined it did not have evidence sufficient to convict Katanga of indirect co-perpetration and notified the parties that it would consider a re-characterization of the charges against Katanga pursuant to Regulation 55.
81) During the Rome Conference, the drafters of the Rome Statute considered the procedural treatment of judicial re-characterization of crimes, but were unable to reach a consensus on the issue.
Comprised of Cadence Virtuoso Liberate and natively integrated Cadence Spectre Circuit Simulator, the solution provides increased performance improvement in the characterization or re-characterization
of ARM Artisan physical IP libraries, while meeting ARM's stringent accuracy targets.
These alleged damages are merely attempted re-characterization
of mental anguish damages.
Moreover, taxpayers will have to review actions taken after the date the check-the-box election is made and before the extraordinary transaction occurs to determine whether any re-characterization
(such as dividend treatment) is needed.
IRS recently released Notice 98-50 clarifying whether a taxpayer who has converted an IRA to a Roth IRA may not only transfer the amount back to a traditional IRA in a re-characterization
, but also subsequently reconvert that amount from the traditional IRA to a Roth IRA.
The prepayment of rent under a lease, and the sale of the property or a leasehold interests, may trigger re-characterization
of the deal by the IRS as an "obligation-shifting" transaction.
The Nuveen preferred securities funds, JTP, JPS and JHP may invest in REITs; a list of funds that are likely to be affected by re-characterization
is posted to www.
The proposed regs provide special rules for the re-characterization
of IRA contributions including Roth IRA and conversion contributions.
Consequently, IP characterization is a significant bottleneck in any chip design process especially as re-characterization
is often required to ensure accurate correlation between the IP and the ever-shifting silicon process.
Funds that may be affected by such re-characterization
include the Nuveen Real Estate Income Fund (JRS), the Nuveen Diversified Dividend and Income Fund (JDD), and the Nuveen Global Value Opportunities Fund (JGV).