Sentences with phrase «income tax purposes in»

Shareholders electing to receive distributions in the form of additional shares will have a cost basis for federal income tax purposes in each share so received equal to the net asset value of a share on the reinvestment date.
Student loans and financial aid count for income tax purposes in very distinct ways.

Not exact matches

The ACCA allows manufacturing companies to depreciate, for tax purposes, the value of newly purchased equipment and machinery at the accelerated rate of 50 per cent per year, reducing their taxable income in the first few years of owning the asset.
And using offshore accounts or holding companys aren't particularly effective methods for shielding income for tax purposes (since offshore accounts are subject to a whole whack of anti-avoidance rules and holding companys are typically subject to more or less the same tax rate as people in the top marginal tax bracket - the Tax Act has tightened up a lot since the 1960s so there really aren't that many «loopholes»tax purposes (since offshore accounts are subject to a whole whack of anti-avoidance rules and holding companys are typically subject to more or less the same tax rate as people in the top marginal tax bracket - the Tax Act has tightened up a lot since the 1960s so there really aren't that many «loopholes»tax rate as people in the top marginal tax bracket - the Tax Act has tightened up a lot since the 1960s so there really aren't that many «loopholes»tax bracket - the Tax Act has tightened up a lot since the 1960s so there really aren't that many «loopholes»Tax Act has tightened up a lot since the 1960s so there really aren't that many «loopholes»).
A participant who is granted an ISO does not recognize taxable income at the time the ISO is granted or upon its exercise, but the excess of the aggregate fair market value of the shares acquired on the exercise date (ISO shares) over the aggregate exercise price paid by the participant is included in the participant's income for alternative minimum tax purposes.
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.
Special rules may apply with respect to certain subsequent sales of the Shares in a disqualifying disposition, certain basis adjustments for purposes of computing the alternative minimum taxable income on a subsequent sale of the Shares and certain tax credits which may arise with respect to optionees subject to the alternative minimum tax.
You were married in a state that recognizes same - sex marriage, you are considered «married» for Federal income tax purposes.
In addition, the amount of the fund's income distributions will vary over time and the breakdown of returns between fund distributions and liquidation proceeds will not be predictable at the time of your investment, resulting in a gain or loss for tax purposeIn addition, the amount of the fund's income distributions will vary over time and the breakdown of returns between fund distributions and liquidation proceeds will not be predictable at the time of your investment, resulting in a gain or loss for tax purposein a gain or loss for 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.
If such a sale or disposition takes place in the year in which the participant exercises the option, the income recognized upon the sale or disposition of the shares will not be considered income for alternative minimum tax purposes.
I would personally recommend you reduce equity exposure to 60 % total if and when there is a correction in the bond market, specifically muni bonds for tax purposes based on your income.
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.
If the IRA contribution is deductible, the end result will be a contribution to an IRA that produces a tax deduction, followed by a Roth conversion that causes the income in the IRA to be recognized for tax purposes.
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
In all foreign countries except Canada, we operate through legal entities disregarded for U.S. income tax purposes, and are subject to income tax in both the local country and the U.S. Unremitted earnings from our Canadian subsidiary, which are intended to be permanently reinvested outside the U.S., are not materiaIn all foreign countries except Canada, we operate through legal entities disregarded for U.S. income tax purposes, and are subject to income tax in both the local country and the U.S. Unremitted earnings from our Canadian subsidiary, which are intended to be permanently reinvested outside the U.S., are not materiain both the local country and the U.S. Unremitted earnings from our Canadian subsidiary, which are intended to be permanently reinvested outside the U.S., are not material.
Our effective tax rate differs from statutory rates primarily due to our pass - through entity structure for U.S. income tax purposes, while being treated as taxable in certain states and various foreign countries as well as for certain subsidiaries.
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 all foreign countries except Canada, we operate through legal entities disregarded for U.S. income tax purposes, and are subject to income tax in both the local country and the U.S. Unremitted earnings from our Canadian subsidiary, which we intend to permanently reinvest outside the U.S., are not materiaIn all foreign countries except Canada, we operate through legal entities disregarded for U.S. income tax purposes, and are subject to income tax in both the local country and the U.S. Unremitted earnings from our Canadian subsidiary, which we intend to permanently reinvest outside the U.S., are not materiain both the local country and the U.S. Unremitted earnings from our Canadian subsidiary, which we intend to permanently reinvest outside the U.S., are not material.
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.
We have some clients who maybe this is the last year that they're getting significant income, and, could frontload donations in that year for 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.
The researchers classify possession of virtual currency depending on its purposes either as inventory, intangible fixed assets or deferred assets, and try to explain accounting processing and income tax treatment of the virtual currency in accordance with these classifications.
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.
For tax purposes, virtual currencies are treated as capital assets or income depending on whether the virtual currency was held for investment purposes, or if the virtual currency was received as a form of compensation (e.g., if the donor is a miner or received compensation in the form of virtual currency).
For the purpose of evaluating Medicare tax exposure, it's important to know that «unearned» net investment income includes net rental income, dividends, taxable interest, net capital gains from the sale of investments (including second homes and rental properties), royalties, passive income from investments in which you do not actively participate (such as a partnership), and the taxable portion of nonqualified annuity payments.
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;
Many who took Canada up on the offer bought expensive real estate in Vancouver, parked their families there and paid little or no income tax because they continued to work and, ostensibly, reside overseas (at least for tax purposes).
And if it be responded that Americans give money to charities because it's advantageous to do so for income tax purposes, well, let's be grateful that, in affording full deductibility to charitable giving, the tax code got something right.
Even though, for social security tax and Medicare tax purposes, you are considered a self - employed individual in performing your ministerial services, you may be considered an employee for income tax or retirement plan purposes.
Canada, in contrast, for example, treats death as a deemed sale of capital assets to the inheritors under its income tax, which makes an inheritance tax somewhat less important for revenue protection purposes.
Nixon's campaign said her true income was about $ 1 million in 2017, noting that the overall figure of $ 1.5 million does not reflect some expenses incurred by Nixon's corporation, while it does include receipts from the sales of securities which are not classified as income for tax purposes.
While land is pooled, the landowner is taxed as if the land is in direct ownership so for income tax purposes, rents are taxed in the hands of the landowner.
The purpose of LITRG's response is to highlight what it sees as some current barriers to work in areas such as income tax, VAT, NIC, and tax credits.
And in New Jersey, where local property taxes are a much bigger concern than state income taxes, incoming Democratic governor Phil Murphy and two Democratic congressmen have floated a proposal to create a charitable foundation similar to the one being contemplated for California and New York, but with property - tax purposes targeted and a new state tax credit created against property - tax liability.
«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.
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.
Payments reported on this form are treated in the same manner as Social Security benefits for income tax purposes
You become a resident of Canada for income tax purposes when you establish significant residential ties in Canada, usually on the date you arrive in Canada.
In addition, IPP assets are creditor - proof: always a plus for the self - employed; and as with traditional Registered Pension Plans, pension income can be split up to 50 % with one's spouse, for income tax purposes (pension splitting).
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