Sentences with phrase «federal tax purposes as»

Donations to Planned Parenthood Advocates of Arizona are not deductible for federal tax purposes as a charitable contribution or business expense, and may be used for political purposes, such as supporting or opposing candidates.

Not exact matches

Riverwalk is an easy target because it is highly visible, has a large price tag, and is financed with a federal loan backed by a local motor fuel tax that, some argue, could be better used for purposes such as municipal schools.

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.

Notice 2014 - 21 answered 16 questions, but also provided an avenue for answering even more, by stating that virtual currency is to be treated as property for federal tax purposes.

Persons that for U.S. federal income tax purposes are treated as a partner in a partnership holding shares of our Class A common stock should consult their tax advisors.

If an entity or arrangement treated as a partnership for U.S. federal income tax purposes holds shares of our common stock, the tax treatment of a person treated as a partner generally will depend on the status of the partner and the activities of the partnership.

Our post-offering organizational structure will allow the Continuing LLC Owners to retain their equity ownership in Desert Newco, an entity that is classified as a partnership for U.S. federal income tax purposes, in the form of LLC Units.

Desert Newco is currently, and will through consummation of the reorganization transactions, be treated as a partnership for U.S. federal and most applicable state and local income tax purposes.

The IRS also says in Notice 2014 - 21, «For federal tax purposes, virtual currency is treated as property.

For example, the Internal Revenue Service regards bitcoin as property for federal tax purposes.

Individuals in other arrangements, such as civil unions, registered domestic partnerships, or other similar arrangements, that aren't recognized as a valid marriage under relevant state law won't be treated as married or as spouses as defined in this policy for federal tax purposes.

The Company is treated as a partnership for U.S. federal and most applicable state and local income tax purposes.

SSE Holdings will continue to be treated as a partnership for U.S. federal income tax purposes and, as such, will not be subject to any entity - level U.S. federal income tax.

The 2016 Plan has been designed to permit the administrator to grant certain awards in its discretion that qualify as performance - based for purposes of satisfying the conditions of Section 162 (m), thereby permitting us to receive a federal income tax deduction in connection with such awards.

as a transaction that is generally tax - free, for U.S. federal income tax purposes, under Sections 355 and 368 (a)(1)(D) of the Code.

If we pay distributions on our common stock, those distributions generally will constitute dividends for U.S. federal income tax purposes to the extent paid from our current or accumulated earnings and profits, as determined under U.S. federal income tax principles.

It does not discuss all aspects of U.S. federal income taxation that may be relevant to particular holders in light of their particular circumstances or to holders subject to special rules under the Code (including, but not limited to, insurance companies, tax - exempt organizations, financial institutions, broker - dealers, partners in partnerships (or entities or arrangements treated as partnerships for U.S. federal income tax purposes) that hold HP Co. common stock, pass - through entities (or investors therein), traders in securities who elect to apply a mark - to - market method of accounting, stockholders who hold HP Co. common stock as part of a «hedge,» «straddle,» «conversion,» «synthetic security,» «integrated investment» or «constructive sale transaction,» individuals who receive HP Co. or Hewlett Packard Enterprise common stock upon the exercise of employee stock options or otherwise as compensation, holders who are liable for the alternative minimum tax or any holders who actually or constructively own 5 % or more of HP Co. common stock).

SCH was treated as a partnership for U.S. federal income tax purposes, and as such, was not subject to any U.S. federal entity - level income taxes.

As discussed above, notwithstanding receipt by HP Co. of a private letter ruling from the IRS and / or opinions of counsel and other external tax advisors, the IRS could assert that the distribution does not qualify for tax - free treatment for U.S. federal income tax purposes.

It is a condition to the distribution that HP Co. receive (i) a private letter ruling from the IRS and / or one or more opinions from its external tax advisors, in each case, satisfactory to HP Co.'s board of directors, regarding certain U.S. federal income tax matters relating to the separation and related transactions, and (ii) an opinion of each of Wachtell, Lipton, Rosen & Katz and Skadden, Arps, Slate, Meagher & Flom LLP, satisfactory to HP Co.'s board of directors, regarding the qualification of the distribution, together with certain related transactions, as a transaction that is generally tax - free, for U.S. federal income tax purposes, under Sections 355 and 368 (a)(1)(D) of the Code.

We believe that the Continuing LLC Owners generally find it advantageous to hold their equity interests in an entity that is not taxable as a corporation for U.S. federal income tax purposes.

Desert Newco is currently, and will be through consummation of the Reorganization Transactions, treated as a partnership for U.S. federal and most applicable state and local income tax purposes.

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.

These entities are now owned 100 % by us or our subsidiaries, and are treated as a consolidated group for federal income tax purposes.

However, if we do make distributions on our Class A common stock, those payments will constitute dividends for U.S. tax purposes to the extent paid from our current or accumulated earnings and profits, as determined under U.S. federal income tax principles.

GLPI elected to be taxed as a real estate investment trust («REIT») for United States federal income tax purposes commencing with the 2014 taxable year.

Our post-offering organizational structure will allow the Continuing LLC Owners to retain their equity ownership in Desert Newco, an entity that is classified as a partnership for U.S. federal income tax purposes, in

Furthermore, we will calculate the state and local income tax savings by applying this 5 % rate to the reduction in our taxable income, as determined for U.S. federal income tax purposes, as a result of the tax attributes subject to the TRAs.

The group incentive nature of employee stock ownership and profit sharing makes this an effective way to create and reinforce a sense of common purpose, and to encourage higher commitment and productivity.23 It is also the case with ESOPs that the new ownership might not be viewed by the firm in the same way as other added compensation because the ownership is financed through loans to buy new capital as company stock, with Federal tax incentives, and the shares are not paid as normal wages and benefits out of company budget reserved for this purpose.

The information provided is not written or intended as specific tax or legal advice and may not be relied on for purposes of avoiding any Federal tax penalties.

However, individuals in other arrangements, such as civil unions, registered domestic partnerships, or other similar arrangements, that are not recognized as marriage under the relevant state law, will not be treated as married or as spouses as defined in this policy for federal tax purposes.

Taxes: Investors should note that even though the dividends are reinvested and that no cash from the dividends was paid to the investor, for federal income tax purposes, the investor will be treated as having received dividend income on the dividend payment date.

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.

NXRT intends to qualify and elect to be taxed as a real estate investment trust, or REIT, for U.S. federal income tax purposes, commencing with its first taxable year of operations as a separate public company.

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.

The Trust is classified as a «grantor trust» for US federal income tax purposes.

• the Trust fails to qualify for treatment, or ceases to be treated, as a grantor trust for US federal income tax purposes, and the Trustee receives notice from the Sponsor that the Sponsor determines that, because of that tax treatment or change in tax treatment, termination of the Trust is advisable;

A Shareholder that is not a US Shareholder as defined above (other than a partnership, or an entity treated as a partnership for US federal income tax purposes) is generally considered a «Non-US Shareholder» for purposes of this discussion.

the Trust fails to qualify for treatment, or ceases to be treated, as a grantor trust for US federal income tax purposes, and the Trustee receives notice from the Sponsor that, because of that tax treatment or change in tax treatment, termination of the Trust is advisable;

For federal income tax purposes, you may deduct as a charitable contribution the price of this ticket less $ 50, our good - faith estimate of the value of the goods or services received.

In the past he has advocated for federal spending as a means of promoting economic growth and he believes in providing tax incentives to businesses for the purpose of job creation.

Contributions to AMERICAblog are not deductible as charitable contributions for federal income tax purposes.

Contributions to the PCCC are not deductible as charitable contributions for federal income tax purposes.

Since contributions would be both deductible and trigger the credit, the effective credit would be between 91 percent and 94 percent.31 This proposal provides relief from the SALT cap because the contribution can be deducted from income for federal tax purposes, just as the State and local tax was prior to TCJA.

The bill itself lays out a series of employees who would not be covered by the guidelines, such as those workers who sell subscriptions and are treated as employees for federal tax purposes.

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.

STEP TWO: Perry moves company address to a Capital Prep, a Hartford Public School and registers it as a charter school management company for purposes of the federal tax code: http://www.guidestar.org/organizations/43-4669846/capital-preparatory-schools-incorporated.aspx

On average, the federal government contributes about 10 percent to the total amount spent on public education, but these dollars account for a larger portion of many high - poverty districts» budgets.11 For example, Los Angeles Unified School District and Chicago Public Schools — both high - poverty districts — receive about 15 percent of their budgets from the Education Department.12 These dollars serve essential purposes, such as supplementing services for low - income students, defraying the cost of individualized education programs for students with disabilities, and compensating for a loss of property tax due to federally owned land.

Perry also registers CAPITAL PREPARATORY SCHOOLS INCORPORATED as a charter school management company for purposes of the federal tax code: http://www.guidestar.org/organizations/43-4669846/capital-preparatory-schools-incorporated.aspx

A RAM truck typically qualifies as Section 179 property for U.S. Federal Income Tax purposes.