Four clarification requests and eleven recasts surfaced.
According to Lyster and Ranta (1997) recasts are the most frequent form of implicit correction.
Indeed, even though three of the four examples (Examples 1, 2, and 4) illustrate transactions that are consistent with the subchapter K rules and are not recast by the Commissioner, the holdings are qualified by the foreboding phrase "[a]bsent other facts"--leaving one to wonder what facts may tip the scale toward recasting the transactions.
with a principal purpose of substantially reducing the present value of the partners' aggregate federal tax liability," the Commissioner may recast the partnership or its transactions.
For small-value arrangements, settlement recasts may be able to address both liquidity and credit risk without serious systemic implications.
In a large-value netting arrangement, the recast of the settlement could remove significant credits that other participants were relying on to meet their own obligations and thus cause them to be unable to settle.
The LR doctrine disregards the independent tax consequences of each step in the LR transaction and, instead, generally recasts the LR transaction as follows: (1) a Sec.
368(a) recast (i.e., a cross-chain D reorganization) or the TASCO recast (a distribution by T's alter ego), then T or the alter ego should recognize gain on the distribution of the NB asset.
* Revenue of $1.2 billion, up 4.5 percent versus recast
However, he is aware that his character was recast
. "In thinking about bringing him back, we reached out to let him know we were doing that," she said (per the (https://www.hollywoodreporter.com/live-feed/crazy-girlfriend-recasts-greg-skylar-astin-1132419) Hollywood Reporter ).
Optimists are thin on the ground now, with regard to this year at least, as council recast
the number of homes they hope to build, rejig promised cuts in unemployment and recast
predictions for new business starts.
Release date- 30072019 - PHILADELPHIA - FMC Corporation (NYSE: FMC) today reported second quarter 2019 revenue of approximately $1.2 billion, an increase of 4.5 percent versus recast
second quarter 2018, driven by strong growth in Brazil, India and EMEA.