Sentences with phrase «federal tax purposes in»

Not exact matches

Section 162 (m) of the Internal Revenue Code imposes limitations on the deductibility for corporate federal income tax purposes of remuneration in excess of $ 1 million paid to the chief executive officer, chief financial officer and each of the three next most highly compensated executive officers of a public company.

You were married in a state that recognizes same - sex marriage, you are considered «married» for Federal income 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.

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.

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

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 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.

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).

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.

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.

Investors participating in this offering will, by contrast, hold equity in GoDaddy Inc., a Delaware corporation that is a domestic corporation for U.S. federal income tax purposes, in the form of shares of our Class A common stock.

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.

In addition, certain events that may or may not be within the control of HP Inc. or Hewlett Packard Enterprise could cause the distribution and certain related transactions to not qualify for tax - free treatment for U.S. federal income tax purposes.

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.

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.

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.

Marriott International said it anticipates the receipt of an IRS private - letter tax ruling in September, confirming that the distribution of shares of Marriott Vacations Worldwide common stock will not result in the recognition, for U.S. federal income tax purposes, of income, gain or loss by Marriott International or Marriott International shareholders, except, in the case of Marriott International shareholders, for cash received in lieu of fractional shares.

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.

Any Social Security that is included in your Adjusted Gross Income (AGI) for federal purposes can be subtracted out of your AGI on your South Carolina tax return.

• 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;

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;

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 creatioIn 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 creatioin providing tax incentives to businesses for the purpose of job creation.

«I believe that it is important that the Treasury and the IRS issue guidance or a formal opinion letter whether taxpayer contributions to state authorized trust funds, partially reimbursed by credits reducing state and local income taxes, will be considered deductible for federal tax purposes,» Faso wrote in the letter.

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.

Consistent with IRS guidelines, only the excess of the contribution over the fair market value of any items received in exchange for a contribution is deductible for federal tax purposes.

In certain circumstances, the U.S. Internal Revenue Code requires that individual income taxpayers report the refund of excess state or local income tax payments received by the taxpayer as income for federal income tax purposes.

In this case, the purpose is NOT to limit federal estate taxes but rather to enhance the likelihood of qualifying for «need based» Medicaid benefits without having to «spend down» the estate assets.

After the ruling, any same - sex couple that was married in a state that recognized same - sex marriage would then be treated as married for federal tax purposes.

An employee working in the state is not required to file a separate W - 4 for state tax withholding purposes, unless the employee claims a smaller number of exemptions from those claimed for federal tax withholding purposes.

3 If you make the five - year election to prorate a lump - sum contribution that exceeds the annual federal gift tax exclusion amount and you die before the end of the five - year period, the amounts allocated to the years after your death will be included in your gross estate for tax purposes.

The federal government determined that millions in taxes were being drained off each year because of the way investment property sales have been treated for tax purposes.

It stated, ``... the IRS will not assert that any taxpayer has understated his federal tax liability by reason of the receipt or personal use of frequent flyer miles or other in - kind promotional benefits attributable to the taxpayer's business or official travel... This relief does not apply to travel or other promotional benefits that are converted to cash, to compensation that is paid in the form of travel or other promotional benefits, or in other circumstances where these benefits are used for tax avoidance purposes.»

Any amount of debt forgiven by a creditor is generally considered to be income for tax purposes, so you will have to pay taxes on the amount forgiven when you file your federal income tax return in the year the debt forgiveness occurs.

A second level, that we might call savings level 2, would be realized in the form of a lower federal estate tax at the time of the asset owner's death when the gross estate is tallied for federal estate tax purposes.

Distributions are taxable to you for federal income tax purposes, whether or not you reinvest these amounts in additional Fund shares.

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.

Broadly speaking, when individuals or businesses set up corporate entities in low or no - tax foreign jurisdictions for the purposes of avoiding taxes in their home countries, it raises serious questions about how the federal government should address it, including expanding the responsibilities of the Canada Revenue Agency to tighten enforcement.

This document contains final regulations that provide transition rules providing that executors and other persons required to file or furnish a statement under section 6035 (a)(1) or (2) regarding the value of property included in a decedent's gross estate for federal estate tax purposes before June 30, 2016, need not have done so until June 30, 2016.

Note that the top of the form states in bold italics that «An IRS individual taxpayer identification number (ITIN) is for federal tax purposes only.»

It says that «A U.S. holder's receipt of the merger consideration in exchange for shares of our common stock will generally be a taxable transaction for U.S. federal income tax purposes.»

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.

If you used the standard deduction, then, Yes, the state tax refund that you received in 2016 is not taxable income for Federal income tax purposes, and it is not taxable income for State purposes either.

For example, if you live in Nova Scotia, and you pay tax at the top combined federal / provincial marginal tax rate of 54 per cent, your tax cost of borrowing $ 100,000 for investment purposes, using a secured line of credit at bank prime rate (currently around 3.45 per cent), is only $ 1,587 annually, assuming the interest is fully tax deductible.

In a community property states only, a husband and wife who are the sole members of a two member LLC may be considered a single member disregarded LLC for Federal tax purposes — check with your tax or legal advisors to discuss this more thoroughly.

For transfers at death, the marital deduction applies only to property included in the gross estate for federal estate tax purposes.

In many cases, the cost of these products may be tax deductible for purposes of Federal and / or State income tax.

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

Your redemptions, including exchanges, may result in a capital gain or loss for federal tax purposes.