The lower court ruling found that Proposition A, which challenged any direct or indirect county support of professional sports facilities, does not apply retroactively
to the Missouri Development Finance Board bonds.
The proposed regulations under section 367(b), described below, cannot be applied retroactively
The high court ruled that retroactively
changing the statute of limitations on a crime violates the Constitution.
These taxpayers assumed they were exempt, but are now being sought by the Department and, if found for audit, being assessed tax, interest and penalties retroactively
Observation: Since these regulations apply retroactively
, it may be necessary for an alien taxpayer to amend his or her U.
232 (1987), would not be applied retroactively
, even to the taxpayer involved in that case.
6621(d) would apply retroactively
if only one were still open.
Since the decision applied retroactively
, lower courts would have dismissed many pending security fraud claims on statute of limitations grounds.
What particularly concerns us, however, is not so much the prospect of a rule deferring the accrual of the deduction for state and local property taxes, but rather the possibility that the IRS might seek to impose such a rule retroactively
to July 18, 1984.
The first commutation - Penn Treaty American Corporation (Penn Treaty) - is effective retroactively
as of May 24.
Diane Shaw, a member of the union bargaining team, said workers voted 258-to-1 to ratify the three-year contract, which is effective retroactively
as of Nov.
2, 1990, the IRS revoked the favorable letter ruling retroactively
to June 11,1984.
Thus, the regulations retroactively
penalize those taxpayers that relied in good faith on the 1987 proposed regulations.
The final regulations are effective retroactively
to January 1, 1989, and apply to contracts entered into on or after that date.
The Wells Notice indicates that the Staff is considering recommending that the SEC bring a civil injunctive action against the Company alleging violations of federal securities laws "arising from MBIA's action to retroactively
reinsure losses it incurred from the AHERF bonds MBIA had guaranteed, including, but not limited to, its entering into excess of loss agreements and quota share agreements with three separate counterparties.