As much as we would all like to believe that this regulation will put an end to controversy in this area, our collective experiences in dealing with capitalization issues
suggests this may be overly optimistic.
Brokers said short-term funds are increasingly flowing out of large capitalization issues
to medium and small caps on the Tokyo market mainly because investors are concerned about the downside risks of international blue chips along with a slump in their U.
Approximately 25 percent of the IRS's time is spent on capitalization issues
Thus, almost 10 years after INDOPCO, the ANPRM was issued to clarify the long-term future-benefit test by outlining the framework for capitalization issues
that the IRS and Treasury expect to provide.
We have used the recent tender offer as an opportunity to reallocate the Fund's portfolio holdings towards smaller and mid-capitalization companies which we believe offer greater potential for growth than do larger capitalization issues
," said Heath B.
TEI also commended Treasury for its efforts to provide timely and administrable guidance, citing the government's response to the September 11 attacks, the re-proposed research credit regulations, the notice on capitalization issues
, and, most recently, the notice on the Rite Aid decision (dealing with the loss disallowance rules).
Further, a government-favorable resolution of this issue could encourage the IRS to pursue other capitalization issues
Many of these public companies must contend with shareholder demands and market capitalization issues
that press the need for continued growth and enhancement of earnings per share.
Indeed, the National Taxpayer Advocate identified capitalization issues
as the most litigated issue for business taxpayers in the 1998 Report to Congress, and there is no sign the controversy has abated.
The outlook revision for Asahi reflects the likelihood that the rating may be raised when the company has stabilized its business position and earnings profile, in light of its success so far in addressing its asset quality and capitalization issues
, Standard & Poor's said.
Therefore, a feasibility analysis should also consider certain ownership and capitalization issues
It appears that as more companies work through their legacy capitalization issues
there is less need for tough terms such as multiple liquidation preferences," said Michael J.