"The window period
is a very favorable solution to the problem of Bicol buses being banned from entering Metro Manila," Lagman said.
In order to remedy the lack of identification, Group C taxpayers should be afforded a window period
to identify transition-period hedging transactions as hedging transactions for tax purposes.
Board member Ariel Inton on Tuesday said the fourhour window period
was granted to 236 provincial buses "after (their operators) in Bicol and political leaders (in that region) made an appeal and we found out that these buses usually arrive in Metro Manila between midnight and 4 a.m.
Allsteel,(37) employees who tried to retire under a collectively bargained early retirement window and were told that their "official" retirement, under the terms of the retirement plan, would be deemed to occur after the close of the window period
, had a claim against their employer.
To be eligible for the 30-day window period
under paragraph 6.04, however, a taxpayer must not have received written notice "specifically citing the method or sub-method to be changed." This written notice may be provided by disclosure of IRS's examination plan, issuance of information document requests, notification of proposed adjustment, or income tax examination changes.
Under the policy, trucks plying C5 and Katipunan are allowed to use only the second innermost lane daily (including Sundays and holidays) during the window period
of the existing MMDA truck ban, which is from 10 a.m.
In this ruling, all wells had been spudded and drilled to their total depth before the close of the window period
, and were scheduled to be completed before the end of 1993.
Under the new revenue procedure, special transition rules apply if the taxpayer is both (1) under IRS examination on March 23, 1992, and (2) not within either the 120-day or 30-day window period
Protests, however, led city officials to grant a window period
to truckers from 10 a.m.
The window period
prevents the related parties from churning goodwill or going concern value from unamortizable status under prior law to an amortizable asset under new law.
The declining economy, the effect of the Persian Gulf crisis on markets, and general business exigencies (including the need to secure regulatory approval in respect of certain transactions) have made closing transactions difficult, if not impossible, within the window period
allowed by the revised regulations.
Negotiations prompted by a truck holiday, however, led to the granting of a window period
between 10 a.m.