In either case, the IRS reasoned, the taxpayer would have the benefits and burdens of ownership, and the opportunity for gain and risk of loss
on a sale to a third party.
Under the current regulations, there is uncertainty about how partners should share a partnership liability when overlapping economic risk of loss
1.752-2(b), all statutory and contractual obligations relating to the partnership liability are taken into account for purposes of determining the economic risk of loss
. These obligations include guarantees, indemnifications, reimbursement agreements, and other obligations running directly to creditors or to other partners.
A comparison of knowledge levels before and after a consumer seminar indicates that individuals seem to have a better understanding of the risks associated with nondeposit investment products: 91 percent know these products are not FDIC-insured, compared with 65 percent before the seminar; 87 percent know these products carry the risk of loss
of principal, compared with 72 percent before the seminar.
Generally, the economic risk of loss
of the deductions attributable to a member recourse loan would be borne by the lending or guaranteeing member, thereby achieving conformity between Secs.
For example, in response to management's objective of minimizing the risk of loss
from changes in market conditions, the entity may enter into derivatives as hedges.
If passed, the legislation would effectively pass the risk of loss
for defects in design and construction to the owner after seven years from the certificate of occupancy issue date.
The approaches to ensuring safe and efficient use of the financial markets by the unsophisticated vary and include restricting their access to certain markets, providing guidance for their investment and risk management practices, encouraging them to obtain independent advice, encouraging diversification of their portfolios, and shifting some of the risk of loss
from the unsophisticated customers to the dealer by establishing special responsibilities for dealers' transactions with their less sophisticated customers.
752 provide that a partner's share of a recourse partnership liability equals the portion of that liability, if any, for which the partner or related person bears the economic risk of loss
KPERS' investment consultants advised that the retirement system not make such investments in Kansas companies because of the high risk of loss