Αποτελέσματα Αναζήτησης
18 Δεκ 2020 · Taxpayer’s intent was to make an election under § 168(h)(6)(F)(ii) to be treated as a taxable entity from inception, but failed to make an election on a timely filed tax return. This failure was inadvertent and Taxpayer is not using hindsight in requesting relief.
§ 168(h)(6)(F)(ii) election is a regulatory election. Sections 301.9100-1 through 301.9100-3 provide the standards the Commissioner will use to determine whether to grant an extension of time to make the election. Section 301.9100-2 provides automatic extensions of time for making certain elections. Section
1 Φεβ 2020 · The election also allows a buyer to obtain the benefits of an asset purchase for federal income tax purposes while respecting the form of the transaction as a stock sale for business, legal, and certain non-U.S. tax purposes.
1 Μαΐ 2018 · New target is deemed to purchase all of the assets of old target at the end of the disposition date but before the deemed liquidation. If new target qualifies as an S corporation and desires to be an S corporation, it must make a new election under Sec. 1362 (a) (Regs. Sec. 1. 336 - 2 (b) (1) (ii)).
4 Ιαν 2019 · Taxpayer had made the §168(h)(6)(F)(ii) election). Taxpayer filed its Form 1120 for Year 2 and Year 3, consistent with its Year 1 return, relying on Partnership K-1’s, which used accelerated depreciation rates.
18 Νοε 2018 · However, to get this treatment the taxable subsidiary must make an election under Internal Revenue Code section 168(h)(6)(F)(ii). The effect of this election is that dividends or interest, paid from the taxable subsidiary to the nonprofit parent, are taxable as Unrelated Business Income.
1 Αυγ 2019 · The IRS has issued guidance allowing a taxpayer to make or revoke certain bonus depreciation elections that were potentially affected by the Tax Cuts and Jobs Act changes to the bonus depreciation rules.
