Television JSA Attribution Rule
-- Joint Sales Agreements (JSAs), the practice of one station selling ad spots for another in exchange for a portion of the proceeds, are legal, legitimate, and proper ways to generate efficiencies for local broadcasters, especially for smaller ones that may not have the capacity or the expertise to run a full ad shop.
In addition to the increased systemic risk and reduction of risk management strategies, the inclusion of derivative transactions for hedging as covered transactions increases the compliance burden, specifically with Section 23A's Attribution Rule
.148 The Attribution Rule
of Section 23 A may now apply to certain affiliate derivative transactions, which creates a difficult and expensive compliance burden on the banks.
In this case, several broadcasters and a non-profit organization individually filed petitions for review of a 2014 FCC Further Notice of Proposed Rulemaking, (6) challenging the agency's delay in defining an eligible entity and a related attribution rule
for television joint sales agreements.
Unintended Consequences of a Broad Attribution Rule
The most significant thing we found in our analysis of the organizational choices made by scientists was that if "the market" designated who gets what share in a co-authored work, it would favor an attribution rule
that did not sum to more than one.
Individual patients' experiences then are aggregated up to the provider level through some type of patient attribution rule
. There are two main dimensions along which attribution rules
can be classified.
The Antitrust Modernization Commission (AMC), (3) some commentators, (4) at least one federal appellate court, (5) and (briefly) the Antitrust Division, (6) have embraced the "discount attribution rule
" as at least an initial step in evaluating bundled discounts under section 2.
The diversity order also intended to modify the equity-debt plus attribution rule
and allow an interest holder to exceed the 33% ownership limit without triggering attribution.
The "estate/beneficiary" attribution rule
. Under this rule, stock owned by a beneficiary of an estate is considered constructively (treated for tax purposes as if it were actually) owned by the estate.
At least when the attribution rule
for trusts holding investment companies was enacted in the mid-1980s, the deferral rules that applied to trusts alone were only modestly restrictive, as discussed earlier.
, and the revenue-based eligible entity standard for ownership diversity purposes.