Sentences with phrase «federal income tax purposes which»

The change in the current tax law regarding MLPs could result in the MLP being treated as a corporation for federal income tax purposes which would reduce the amount of cash flows distributed by the MLP.

Not exact matches

A statutory nonemployee, which includes direct sellers and licensed real estate agents, is treated as self - employed for all federal tax purposes, including income and employment taxes.

Accordingly, notwithstanding receipt of the IRS private letter ruling and / or opinions of counsel or other external tax advisors, the IRS could determine that the distribution and certain related transactions should be treated as taxable transactions for U.S. federal income tax purposes if it determines that any of the facts, assumptions, representations, statements or undertakings that were included in the request for the IRS private letter ruling or on which any opinion was based are false or have been violated.

For purposes of calculating the income tax savings we are deemed to realize under the TRAs, we will calculate the U.S. federal income tax savings using the actual applicable U.S. federal income tax rate and will calculate the state and local income tax savings using 5 % for the assumed combined state and local rate, which represents an approximation of our combined state and local income tax rate, net of federal income tax benefit.

The potential tax benefits from investing in MLPs depend on their being treated as partnerships for federal income tax purposes and, if the MLP is deemed to be a corporation, then its income would be subject to federal taxation at the entity level, reducing the amount of cash available for distribution to the fund which could result in a reduction of the fund's value.

Upon dissolution or winding up of said corporation's affairs, whether voluntary or involuntary, all of its assets then remaining in the hands of the board of directors shall, after paying or making provision for payment of all of said corporation's liabilities, be distributed, transferred, conveyed, delivered, and paid over only to educational, scientific, literary, or charitable organizations that are exempt from federal income tax under section 501 (c)(3) of the Internal Revenue Code of 1986, as amended, and which are not private foundations within the meaning of section 509 (a) of the Internal Revenue Code of 1986, as amended, on whatever terms and conditions and in whatever amounts the board of directors may determine, for use exclusively for educational, scientific, literary, or charitable purposes, except that no distribution shall be made to organizations testing for public safety.

An unfavorable audit will likely result in some portion of the distributions being reclassified as earned income for federal income tax purposes, which results in a deficiency assessment (i.e., a tax bill), interest on those unpaid taxes, and IRS penalties.

The higher tax rate in 2005 compared with 2006 was primarily due to the accrual of regulatory penalties, which are not deductible for purposes of calculating the Company's Federal income taxes.

Thrift Savings Plan payments are taxable as ordinary income for Federal income tax purposes for the year in which they are disbursed.

In the year of disposition the adjustment will be a subtraction for gain attributable to installment payments to be made in future taxable years provided that (i) the gain arises from an installment sale for which federal law does not permit the dealer to elect installment reporting of income, and (ii) the dealer elects installment treatment of the income for Virginia purposes on or before the due date prescribed by law for filing the taxpayer's income tax return.

The deduction is not allowed for any portion of premiums for which you have been reimbursed, have claimed a deduction for federal income tax purposes, have claimed another Virginia income tax deduction or subtraction, or have claimed a federal income tax credit or any Virginia income tax credit.

The fund distributes to shareholders at least annually any net capital gains which have been recognized for federal income tax purposes, including unrealized gains at the end of the fund's fiscal year on futures or options transactions.

This procedure provides a safe harbor under which the Service will not challenge (a) the qualification of property as either «replacement property» or «relinquished property» for purposes of section 1031 of the Code or (b) the treatment of the» «exchange accommodation titleholder» as the beneficial owner of such property for federal income tax purposes, if the property is held in a «qualified exchange accommodation arrangement» (QEAA).

ABCs of Housing Bonds (1993) The 5th edition of the ABCs of Housing Bonds introduces readers to the rules applicable to the financing of multifamily and single - family housing with bonds, the interest on which is not included in gross income for federal income tax purposes.