Congress determined to correct these "uncertainties" by amending the Code to "ensure there is no question that repo participants are afforded the same treatment with respect to the stay and avoidance provisions of the Code in connection with repurchase agreements" as is afforded other market participants under the 1982 amendments [which had created safe harbors
for commodity trades].
As this item explains, qualifying for this re-cently established book safeharbor method is easier than qualifying for other safeharbor methods, but other complexities still face taxpayers using the safe harbor
The personal services safe harbor
requires that the aggregate compensation paid for the services be set in advance and consistent with fair market value in arm's-length transactions.
Regulations section 1.121-3(e)(2) lists specific-event safe harbors
that must occur while the taxpayer owned and used the residence.
The best use of the safe harbor
is to show that you comply with the DMCA standards and are entitled to summary judgment in your favor in any infringement litigation.
Prescott continued, "Our safe harbor
agreement creates a way for individual companies to qualify to be in safe harbor
The Reform Act's most significant component, referred to as the safe harbor
, protects that subset of soft information known as "forward-looking statements." Forward-looking statements include--
In fact, several of the safe harbors
address very specific issues or situations that affect small numbers of physicians.
In instituting a criminal background check procedure, the following safe harbors
should be observed:
This article refers to this set of safe harbors
as "conventional" because they have been the only ones in effect until 1992.
Taxpayers using this safe harbor
are subject to the rules in Regs.
If the EAT holds the property for more than 180 days, the transaction falls outside the safe harbor
, thus subjecting the transaction to general tax and legal principles of exchanges without regard to Rev.