Under these final COI regulations, a contract with a "proration" mechanism providing for the issuing corporation's stock and cash amounts to be prorated, if necessary, so that 40% of the total consideration is in the form of issuing corporation stock and 60% is in cash, should satisfy
the COI requirement, even if the amount of issuing corporation stock issued in the transaction is based on a market value occurring after the binding contract date.
These are but a few of the questions that will arise in assessing whether an enterprise can satisfy
factor (c) in order to recognize a tax benefit.
If consumers are already seeking variety in a product class, the optimal strategy for a brand would be to satisfy
the consumers' desire for variety--but at the same time to encourage as much brand loyalty as possible.
MEMBERS SHOULD SATISFY
THEMSELVES regarding the competence, practices and procedures of any third-party provider, regardless of the type of services provided or the location at which they are performed.
All employer matching contributions and nonelective contributions that are used to satisfy
the safe harbor rules must be nonforfeitable and subject to the restrictions on withdrawals and distributions that apply to an employee's elective deferrals under a 401(k) plan.
This acquisition does not satisfy
the requirements for a statutory merger because V (the combining entity of the transferor unit) does not cease its separate legal existence.
The taxpayer cannot purchase, lease or license and use the software for the intended purpose without modifications that satisfy
the first two requirements.
after severance of employment with M), A would not fail to satisfy
section 403(b)(1)(E) (that is, to treat amounts as elective deferrals--and thus subject to the annual limit--when made in accordance with a one-time irrevocable election).
An employer must satisfy
these criteria: (1) a 50-employee requirement, (2) a notice requirement, and (3) an administrative scrutiny requirement.
The company intends to continue to service and support, and satisfy
the warranty obligations on, the installed base of SenoScan and MammoTest systems as well as fulfill its contractual obligations to provide MammoTest and SenoScan systems to Ethicon Endo-Surgery and Philips, respectively, while it explores strategic alternatives for its RE&S and Service businesses.
However, distributions can be made if the employee proves it is "necessary" to satisfy
an "immediate and heavy financial need.
All technical areas are complete, positive and satisfy
the requirements of the Protocol.
cooperative would satisfy
the requirement for democratic control even if one were to treat its three members as if they were a single entity.
To qualify for the exemption, a FSC and the export property must satisfy
the requirements of tax code sections 921 through 927.