Sentences with phrase «income tax purposes of»

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.

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.

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.

However, your government is already on record for its commitment to allow families with children under the age of 18 to split income for tax purposes; to extend the fitness tax credit to adults; to raise the threshold for Tax Free Savings Accounts to $ 10,000; and to reduce government detax purposes; to extend the fitness tax credit to adults; to raise the threshold for Tax Free Savings Accounts to $ 10,000; and to reduce government detax credit to adults; to raise the threshold for Tax Free Savings Accounts to $ 10,000; and to reduce government deTax Free Savings Accounts to $ 10,000; and to reduce government debt.

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 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.

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.

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.

There is a large body of established tax principles and law for property that apply to cryptocurrency and how the gains, losses, income and transactions are treated for federal tax purposes.

Modified Adjusted Gross Income (MAGI) can qualify you for a number of credits, benefits, and exclusions, which makes it important to calculate for tax purposes.

The Harper government had already promised to use the surpluses to allow income splitting for tax purposes for families with children under the age of 18; to extend the fitness tax credit to adults; and, to reduce debt by $ 3 billion a year.

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.

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).

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.

Accordingly, notwithstanding receipt by HP Co. of the IRS private letter ruling and the tax opinions referred to above, the IRS could assert that the distribution and / or certain related transactions do not qualify for tax - free treatment for U.S. federal income tax purposes.

Accordingly, notwithstanding receipt by HP Co. of the IRS private letter ruling and the tax opinions referred to above, there can be no assurance that the IRS will not assert that the distribution and / or certain related transactions do not qualify for tax - free treatment for U.S. federal income tax purposes or that a court would not sustain such a challenge.

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.

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.

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.

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.

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.

For federal income tax purposes, fund distributions of long - term capital gains are generally taxable at reduced long - term capital gain rates.

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.

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.

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 purpose of a tax - deferred annuity, unlike an immediate annuity, is to build funds to create an income stream at a later date.

• 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;

If you are employed by a congregation for a salary, you are generally a common - law employee and income from the exercise of your ministry is considered wages for income tax purposes.

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.

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.

For the collection of state income taxes, adjusted gross income and itemized deductions are based off the federal IRC, with adjustments for state 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 Chartered Institute of Taxation (CIOT) welcomes today's announcement by the Financial Secretary to the Treasury, Mel Stride MP, that mandation of digital record keeping and quarterly reporting by small businesses and landlords for income tax purposes will be deferred until at least April 2020.

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.

One is to locate intangible property for tax purposes where the person making the intangible property payment is located rather than where the person who is entitled to receive the intangible property payment is located, because the person making the payment often has less freedom to change their location and is often more closely associated with the production of the income.