Distributions in excess of expenses are includable
in gross income and may be subject to an additional 10% tax.
Since the Williams settlement included a $32 million dollar punitive damage award, this amount would be includable
in gross income under the present statutory scheme and in the light of O'Gilvie supra.
At this point, it is now up to the contractor to prove why DCAA is wrong with these calculations, else these are the amounts that will be includable
in the company's rate structure.
Under the new law, if a deferred compensation plan does not comply, deferred amounts will be includable
in income and will be subject to a penalty of interest at the underpayment rate plus 1 percent, and an additional 20 percent tax penalty.
They usually contain a series of "yes/no" questions and a section for includable
points and fees that, when used correctly, will help the lender stay in compliance.
Information goods are excludable if positive access fees are feasible and includable
if negative access fees are feasible; Stegeman studies several cases.
parties have agreed on a broad arbitration clause, an issue arguably includable
within its scope is to be included unless the parties clearly
ESTATE LIQUIDITY- Benefits usually payable Does plan provide cash to family in installments for death taxes and and includable
in the estate settlement costs?
For instance, it is not uncommon for a lease to provide for a management fee of 10 percent of CAM costs with the includable
cost of security capped at perhaps $10,000.
21) Two Tax Court memorandum decisions, rendered post-Burke and filed before the 1991 amendment, held that Title VII amounts awarded for racial discrimination were includable
Considering that a broad range of settlements excludable under prior law will now be includable
in gross income, negotiated settlements of employment discrimination cases will likely be fewer, the number of cases will probably not decrease, and amounts demanded and ultimately recovered by injured employees may be greater than ever.
For some beneficiaries, the portion of their benefits includable
in taxable income was increased from 50 percent to 85 percent, effective in 1994.
This modification provides a "look-through" rule in determining whether certain insurance income currently includable
in gross income under the Subpart F rules should be treated as UBTI.
An additional tax of 10% of the amount includable
in income also would apply unless the distribution is made after the individual dies or becomes disabled.
While the specific composition of tier 2 was left to national discretion, the committee specified several binding limitations on the inclusion of instruments in tier 2, including a 55 percent discount on uurealized gains on securities holdings and a limit on includable
subordinated debt at a level of 50 percent of tier 1 capital.