In the Rules and Regulations section of this issue of the Federal Register, the Internal Revenue Service is issuing temporary regulations relating to the requirement that individuals attach a statement to their income tax return to provide required information regarding foreign financial assets in which they have an interest. The text of the temporary regulations also serves as the text of these proposed regulations. This notice of proposed rulemaking also includes a proposed regulation setting forth requirements for certain domestic entities to report foreign financial assets in the same manner as an individual.
... to any domestic entity which is formed of availed of for purposes of holding, directly or indirectly... the regulations as excepted from the definition of the term ``specified United States person''. Th...
Proposed regulations under Section 704(c) provide that the Section 704(c) anti-abuse rule takes into account the tax liabilities of both the partners in a partnership and certain direct and indirect owners of such partners. The proposed regulations further provide that a Section 704(c) allocation method cannot be used to achieve tax results inconsistent with the intent of subchapter K. The proposed regulations affect partnerships and their partners.
... that, if a partnership is formed or availed of in connection with a transaction a principal pu...(ii) Definition of indirect partner. An indirect partner is any di...
... Saffon that she "no longer m[et] the definition of disability" and terminated her long-term benefiits. Saffon then unsuccessfully availed herself of MetLife's administrative appeals proces...
In the aftermath of September 11, 2001, Attorney General John Ashcroft authorized the U.S. government to use material-witness arrest warrants to detain and investigate terrorist suspects. At that time, existing law permitted this investigatory use, based primarily on the principle that subjective intent is irrelevant in the standard Fourth Amendment context. In al-Kidd v. Ashcroft, the Ninth Circuit Court of Appeals erred in denying former Attorney General Ashcroft qualified immunity. Ashcroft’s decision to permit the government to use a valid material-witness arrest warrant to detain Abdullah al-Kidd did not violate al-Kidd’s constitutional rights, regardless of the government’s subjective intent. Furthermore, assuming that the government’s actions were unconsti...
... combat these problems, the government has availed itself of the option of temporarily detaining witn...23 This definition’s application in the material-witness context, howev...
... such a conference was accorded but not availed of, there will be no conference granted before the... advice from the National Office?(i) Definition and nature of technical advice. (a) As used in thi...
... be explained by a more comprehensive definition, one designed to elaborate on the term in anticipa... asylum when an alien “has voluntarily availed himself or herself” of another country’s prote...
... or applicants for employment" who have availed themselves of Title VII's protections. The Distric...Second, § 701(f)'s general definition of "employee" likewise lacks any temporal qualifie...
criminal act, willful damage, theft offense, bad check, R.C. 2307.60, R.C. 2307.61, triple the value, liquidated damages, treble damages,
... act was established according to the definition of the relevant statute, but rather whether Red Feerris availed itself of other remedies, and whether the matter h...
...(i)(F) would require broker's brokers that availed themselves of the safe harbor to use predetermined... Rule G-43(d) would contain the definitions of terms used in Proposed Rule G-43. Under Propose...
... to file an FBAR due in earlier years, but availed yourself of this extended filing deadline, you gen..., FinCen declined to extend the definition of financial account to include non-U.S. hedge fun...
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