the shares of relevant group companies are excluded
The portion allocable to the personal-use residence is not reported on the return if all the personal-use gain is excluded
On January 8, 2003, the Board voted to apply the FTB's proposed "elimination and basis transfer" approach to intercompany inventory sales and purchases where a water's-edge election had been made and the transferring entity has been excluded
from the water's-edge group.
If a loan is made by a foreign affiliate and the loan is made on capital account, any gain or loss on the repayment or settlement of the loan relating to currency fluctuations between the calculating currency of the affiliate and the currency of the loan will be a gain or loss from excluded
property if the interest on the loan is included in active business income under subparagraph 95(2)(a)(ii).
The Court said a taxpayer must meet two independent requirements before a recovery could be excluded
under section 104(a)(2): (1) the underlying cause of action giving rise to the recovery must be based on tort or tort-type rights and (2) the damages must have been received on account of personal injury or sickness.
Subclause 95(2)(a)(ii)(B): Excluded
Loans under the Act (including compliance with the Act's safe harbor provisions for the exclusion of High-Cost Loans).
The selection process is based on the individual project "promoting social inclusion of socially excluded
localities in the karlovy vary region ii", which aims to support work with families and minors (15-26 years), followed by systemic support social service providers.
Each meets the ownership and use tests and each has a $250,000 excluded
gain and a $20,000 included gain on their individual returns for the year of sale.
The corpus is excluded
from the grantor's taxable estate.
In addition to excluding Interest, Taxes, Depreciation, and Amortization, we have excluded
non-cash expense for legal fees, professional fees, non-cash employee salaries, non-cash bad debt expense (the write-off of a 1998 note receivable), and the non-cash gain on forgiveness of debt for correction of old liabilities.
108 and 1017, the lower-tier member is treated as a DM with excluded
DOI income in the amount of the stock-basis reduction (the look-through rule).