The safe harbor applies only for the third (or second) profitable year and all subsequent years within a five-year (or seven-year) safe-harbor
period that begins with the first profitable year (Regs.
D) to determine whether that transfer meets the safe-harbor
criteria, or should courts look also to any component parts of the overarching transfer (i.e., A ?
401(k)s might not be a good fit for every small business.
2011-29 and permitting taxpayers to elect a broad array of acquisition costs and "success-based" fees, including accounting and legal fees, for the 70-30 safe-harbor
2013-13, issued in January, the IRS gave taxpayers an optional safe-harbor
method to calculate a deduction for expenses of a business use of a residence under Sec.
Arrangements for providing items and services that meet the safe-harbor
requirements would be exempt from enforcement under the federal anti-kickback statute, HHS said.
The IRS issued guidance (Q&A 12 in Notice 89-25) that provided three safe-harbor
methods for satisfying this exception.
The use of safe-harbor
transmittal language becomes particularly germane in those instances where the state boards exercise administrative penalty jurisdiction over non-licensees as well as licensees.
The PATH Act of 2015 made several amendments to the prohibited-transaction safe-harbor
test under Sec.
Given the limited application of the proposed scheme to most of the companies represented by TEI's membership - and the seeming "inevitability" of the ratcheting down of the safe-harbor
percentage as the means of "paying for" the new system (if a funding mechanism is necessary) - the Institute has not previously commented on the proposed regulations.
2015-56, which provides certain retailers and restaurants a safe-harbor
method of accounting for remodel or refresh expenditures on qualified buildings.
* The exchange must be completed within 180 days to receive the automatic safe-harbor