When an affiliated group member borrows funds from a related affiliate
and invests them directly in exempt obligations, Sec.
It generally includes other foreign affiliates
, any person who does not deal at arm's length with the taxpayer, and certain trusts and partnerships.
The current [Bay area] NBC affiliate
will generate $160 million in revenue this year.
Bank subsidiaries of the fourteen companies operating under the 1987 order have therefore been free to fund, and have in fact funded, their section 20 affiliates
subject to sections 23A and 23B.
Two HKNC affiliates
- the Michigan Commission for the Blind and the Kentucky Department of Vocational Rehabilitation - have developed quality programs of service to their deaf-blind citizenry.
In the meantime, taxpayers should be cautious when considering many common transactions involving their foreign affiliates
In addition, an organization applying for exempt status may request (by separate written request submitted with its application for exemption recognition) a determination that it meets the requirements to be an affiliate
of a governmental unit and, thus, is excepted from filing Form 990.
Specifically, the regulations would impose a mandatory provision for all solicitations, contracts, and purchase orders to prohibit State contractors from "shifting" income to out-of-State affiliates
by claiming a deduction for royalties or similar payments to the affiliates
for trademarks, trade names, or other intangible property.
Although an expanded 15-month reporting deadline is better than the original 6-month deadline, foreign affiliates
in some jurisdictions will still be unable to supply complete information for the proposed Form T1134.
On March 5, 1996, draft legislation was released that will impose new and substantial information reporting requirements in respect of the foreign affiliates
of Canadian taxpayers.