The same effective date
must apply to all of the employer's NQDC plans.
Permission to discontinue filing consolidated returns is coincident with the effective date
of the final regulations (i.
Expansion of coverage may be prohibitive given the effective date
of the change.
At a minimum, the effective date
of a subsequently promulgated anti-abuse regulation should incorporate the following limitations:
For this purpose, an election as of the effective date
of the regulations, and an election made at an entity's inception, do not count.
Reflecting to some degree the comments filed on the March 1990 regulations, the effective date
Bank, National Association, after the effective date
of the issuance of the Notes.
It is but one example of the administrative burdens that can be inflicted on taxpayers when rules are drafted without giving sufficient thought to their effective date
Holders of claims and equity interests will be precluded and enjoined from asserting against Able, the liquidation trust and any of the assets or properties of Able or the liquidation trust, any other or further claim or equity interest based upon any act or omission that occurred prior to the effective date
Once it has been determined that an S corporation has a net unrealized built-in gain, it will owe a tax on the net recognized built-in gain that arises during the 120-month period beginning with the effective date
of its S election.
1502-20 regulations were issued in proposed form with a prospective effective date
(February 1, 1991).
The IRS also cautioned that an employer's reasonable, good-faith treatment of an amount as deferred compensation subject to FICA and FUTA for periods preceding the effective date
of the promised regulations may not necessarily be determinative of FICA and FUTA liabilities for periods after the effective date
of those regulations.