Under HB 5018, Laws 2004, pass-through entities
are required to file information returns for tax years beginning after 2003.
classify liabilities based on whether the reporting entity's budgetary resources cover them.
70-23,(22) the IRS sanctioned an exclusion for dividends paid to a taxpayer other than the entity to which the section 482 adjustment had been made, where control existed between the two entities
These rules should be distinguished from the more general rule that a structure with multiple unrelated IE's may be a financing arrangement if each of the entities
qualifies as a conduit under the usual rules.
For example, if the entity conducts business with foreign entities
, the auditor should inquire about any arrangements the entity has made for purchasing foreign currency.
My second comment relates to Per Se entities
revised, after May 8 and before the date the regulations are final.
Qualified subchapter S subsidiaries (QSubs) and certain other single-owner disregarded entities
would be responsible for paying employment and excise taxes under new IRS guidance.
90) Additionally, corporations required to file Virginia tax returns and that are limited partners in such entities
generally would not flow up their pro-rata share of partnership factors in computing their own Virginia apportionment factors.
In the international area, subparagraph (8) provides that the term "corporation" includes 82 listed foreign entities
, such as a Canadian corporation or a French societe anonyme.
Abuses of tax-exempt entities
generally fall into two categories--Sec.
An ongoing objective of a global tax plan it to be alert to the opportunities that exist by creating new entities
within such tax-haven jurisdictions.
Yet with careful thought and cooperation, health care entities
can work with their staffs to foster effective peer review in compliance with the Act while promoting and preserving staff members' hard-earned reputations.