Notice 2002-8 contains guidance for arrangements entered into
before these regulations are effective.
Group B taxpayers -- generally, though not always, through an HC -- timely identified each risk-reducing position entered into
with a third party and also identified the risk held by related members as constituting a hedge transaction for tax purposes.
* IN THE NOT-TOO-DISTANT future, data will be entered into
tiny personal digital assistants, allowing a user to create a spreadsheet, dictate a letter and send a fax, all with voice commands--while riding in a taxi.
As contemplated under the pledge agreements, the trustee, acting as an agent of the taxpayer, entered into
share-lending agreements with the counterparty with respect to the pledged stock.
In February 2000, 57th Street Acquisition LLC entered into
a contract to buy 1 E.
On behalf of Tax Executives Institute, I am pleased to submit these comments on the proposed regulations under sections 446 and 1221, relating to the treatment of hedging transactions entered into
by members of consolidated groups.
The collected data can be entered into
the computer as each count is made (in real time) or added automatically at the end of the count (in batch mode).
parent of that group entered into
the original GRA under Kegs.
In addition, The Rockefeller Group and Morgan Stanley Dean Witter have entered into
an agreement to co-develop 745 Seventh Avenue as a 33-story tower office building at the northern end of Times square.
For this purpose, such transactions are entered into
by taxpayers, in the normal course of business, primarily to reduce the risk of either
(7) The new percentages apply to contracts entered into
after October 13, 1987.
had an income tax treaty with the other jurisdiction; (2) that treaty, contained an excise tax exemption provision and a limitation-on-benefirs article similar to those in the U.S.-Germany income tax treaty; and (3) the treaty entered into
force after May 18, 1992.
Vornado, which owns 2.3 percent of Alexander's common stock, also announced that it has entered into
an agreement to acquire all of the 1,353,468 Alexander's shares (27.1 percent) owned by Citibank, N.A.
David's, an exempt organization that owned and operated healthcare facilities in Texas, entered into
a hospital joint venture with a subsidiary of Columbia/HCA Healthcare Corp.
Nevertheless, Jacobson entered into
a contract of sale with the Bogens providing for a closing on February 1, 1994.