Sentences with phrase «unrelated party»

Several transfer pricing methods, including the comparable and residual profit split methods, do not require use of unrelated party prices as starting points.
Insurance companies therefore avoid accepting unrelated parties as nominees.
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The 482 regs include many pages of comparability adjustments which at every turn show that a starting unrelated party price, even if available, often needs a lot of work before it can be considered a comparable.
A CC0 license granted by party A only waives their rights, and not those of unrelated party B (i.e. Marvel).
Limitation applies to both related party and unrelated party debt.
One reason that Altera should lose in the Ninth Circuit is because the arm's length standard does not, and never has, required a starting unrelated party data point in all cases.
Moreover, large chunks of the 482 rules prove that the arm's length standard is not a brittle instruction to use whatever unrelated party information is available.
More generally, the B.G.P. poses the question of how to establish trust between otherwise unrelated parties over an untrusted network like the Internet.
It's astonishing to think unrelated parties, i.e. the great unwashed, occasionally buy this stock.
Nominating unrelated parties, i.e. those without an insurable interest in the insured's life increases the risk for the insurer.
In a case like this I advise my clients to get a loan from or partner with unrelated party who is not a «disqualified person».
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One amicus brief points out that Section 482's reference to pricing «commensurate with income» only makes sense if the arm's length standard embraces transfer pricing that is not bound to unrelated party pricing.
Registration of unrelated parties as the nominee is usually not approved by the insurers since it quite often increases their risk, as the concept of insurable interest comes into question.
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Your estate may retain ownership of the property and must pay off the loan in full or the property can be sold to an unrelated party for the lesser of the unpaid mortgage balance or 95 % of appraised value
It is sometimes described as «garage sale value,» or how much actual cash you would receive by selling the item to an unrelated party.)
First, you can't accept a gift from just anyone — no, it's not trampy (I'm not your mother), but FHA doesn't believe that an unrelated party is likely to actually fork over the funds while expecting nothing in return.
Unnecessary risk is two unrelated parties with no economic interest betting on whether the company can survive or not; such a bet should be regulated as gambling.
You can do other little things while running around on the field, such as the aforementioned cheering (approach an unrelated party's player, press A to bring up their contextual menu and then hit A again to select «Cheer»), which gives that player's party an attack boost and increases the amount of money that player will make from that battle.
Suppose a contract is signed by two parties, Party A and Party B. Suppose that the contract stipulates a severe financial penalty to be paid by Party A depending on whether or not an unrelated party,...
The cheque is drawn from an unrelated party.
This case has a nice discussion of the leading cases on attorney's charging liens, and concludes public policy favored the priority of an attorney lien — after all, the judgment creditor might not have received anything but for the collection efforts of judgment debtor's attorneys as against the unrelated party.
You may want to check with FHA to see if their non occupying co-borrower program is exclusive to related parties (parent to child) or if this could apply to unrelated parties.
Flopping involves fraud because the real estate transaction is supposed to be an «arms length transactions» — a transaction between independent and unrelated parties; there should be no collusion between the parties that results in unfairness or injustice to the seller.
Furthermore, to qualify for the first tax credit noted above, any electricity produced on site must be sold to either an unrelated party or metered and monitored by a third - party.
Exchange Accommodation Titleholder («EAT»): An unrelated party (i.e. Exeter Reverse 1031 Exchange Services, LLC) that holds the qualified indicia of ownership (customarily the title) of either the replacement or relinquished property in order to facilitate a reverse and / or build - to - suit tax - deferred, like - kind exchange transaction pursuant to Revenue Procedure 2000 - 37.
An unrelated party (EXETER 1031 Exchange Services, LLC) who participates in the tax - deferred, like - kind exchange to facilitate the disposition of the Investor's relinquished property and the acquisition of the Investor's replacement property.
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