The ruling holds that, similar to the proposed regulations, if an affiliated group member borrows from an unrelated party and directly loans the funds to a related dealer affiliate
for the purpose of carrying on the dealer's general business, the disallowed interest expense allocation is both calculated and applied at the dealer level.
The regulations governing the recomputation of the surplus accounts of affiliates
after a section 93 election is made have also been completely revised and are very complex.
And, although Cornwell owns nine of those 26 stations, he still felt inclined to pay for affiliate
programming while more established majority-owned stations receive payment for such an arrangement.
I will also discuss the final changes the Board made last year to the revenue test that the Board uses to determine compliance with section 20 of the Glass-Steagall Act and to firewalls regarding cross-marketing between a bank and a securities affiliate
, and officer, director, and employee interlocks between two such companies.
In recognition of the above mentioned deficits in service delivery to individuals over age 21 who are deaf-blind, the Transition Subcommittee applied to the Helen Keller National Center for funding to establish an affiliate
position to work closely with the transition program and address the needs of individuals who are already out of school.
A number of problems affecting taxpayers owning foreign affiliates
that were identified by the Joint Committee and others were not addressed in the technical bill.
1) As explained in the text that follows, there is currently some dispute about how the State's current tax rules apply to royalty payments paid to out-of-State affiliates
The agreement could be as narrow, say, as one particular controlled foreign affiliate
, or broadly applicable to several categories of information for all of the taxpayer's foreign affiliates