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.
Based on all the facts of record, including the commitments provided by Bank limiting the activities of the proposed office, it has been determined that Bank is subject to a supervisory framework that is consistent with the activities of the proposed representative office, taking into account
the nature of such activities.
In computing Pennsylvania's franchise tax, Unisys calculated its tax base with regard to its own net worth and average income, using a three-factor apportionment formula taking into account
its own payroll, tangible property, and sales for those years.
Fitch's Distressed Recovery (DR) ratings, introduced in April 2006 across all sectors of structured finance, are designed to estimate recoveries on a forward-looking basis while taking into account
the time value of money.
Specifically, the adjustment is computed by taking into account
amounts paid or incurred in the period beginning with the first day of the tax year that includes Jan.
If, taking into account
all the facts and circumstances, the benefits and burdens of ownership have been transferred to the buyer, the transaction is a sale.
In Europe, the decision was made to maintain higher staffing levels rather than adjust for the below-budget client revenue in the quarter because of the scheduled start-up there of a large project for a major client on July 1 and taking into account
European employment laws.
The court had to decide if the guaranty on the loan was a liability for insolvency purposes, taking into account
the fact that the note was contingent on the occurrence of a bankruptcy filing.
Taking into account
the increasing use by corporations of partnerships and limited liability companies for joint ventures, it is noteworthy that ISOs cannot be granted to employees of partnerships (or other entities, such as limited liability companies, that are treated as partnerships for tax purposes), even if the partnership is controlled by a corporation that has adopted or could adopt an ISO plan.
By not taking into account
the scope of Appendix 3 and the significance of Appendix 4, the district court has found Lars-Eric Petersson guilty of something that he was not even charged with - a loss attributable to participants who are not even covered by Appendix 3.
The shareholder may realize gain or loss on the deemed transfer of the S corporation's assets (including the installment obligation) to the shareholder, after taking into account
the effect of the deemed sale of the assets; see Temp.
Similar rules apply for taking into account
original issue discount and premiums.