752-3(b) would modify the third-tier rules to allow a partnership to allocate
a portion of the nonrecourse liability, based on the excess Sec.
In some cases, the failure to allocate
a GST tax exemption or the possibility of a transfer subject to a GST tax may not be discovered for many decades.
755-2T, ABC allocates
$30,000 of basis to goodwill.
In the past, "scheduled" and often costly downtime was required to allocate
storage resources to servers.
This recapture rule applies to any section 467 rental agreement that is a leaseback or a longterm agreement that is not disqualified but which allocates
to any rental period fixed rent that, when annualized, exceeds the annualized fixed rent allocated to any preceding rental period.
Thus, any other "facts and circumstances" method, such as specific identification, burden rate, standard cost or "other reasonable allocation methods," must allocate
costs to specific inventory items; see Regs.
SOP 93-6, however, generally provides that when a company allocates
shares to participants' ESOP accounts, a compensation expense results that is measured by the fair market value of the stock on the allocation date.
861-10T(c) contains a new rule for integrated financial transactions that allocates
interest expense directly to income from an investment funded with amounts borrowed for the purpose of acquiring the investment.
The budget allocates
approximately $365 million from the budget contingency fund, which derives its resources largely from sweeping other funds balances and by elimination of the 2% general fund budget cushion.
Although a trustee who allocates
capital gain to trust income with a power to adjust must do so "reasonably and impartially," the regulations neither define nor illustrate this concept.
all participants benefit, allocates
a joint effort's cost in proportion to the amount of cost that would have been incurred separately.
the BIG or BIL to the contributing partner.
Those proposed regulations said, in effect, a profit-sharing plan that allocates
contributions based on age does not necessarily discriminate in favor of the highly compensated.
ITU World Radio Conference Allocates
Additional 455 MHz of Spectrum for WLAN use, Including 355 MHz for Mixed Outdoor/Indoor Use
The plan allocates
its administrative expenses among employees' accounts based on the ratio of each account balance to total account balances.