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Demystifying IRC Section 965 MathLougen, Mary BethCPA Journal
If the allowance of an application, credit, or refund of a decrease in tax determined under section 6411(b) is otherwise prevented by the operation of any law or rule of law other than section 7122, such application, credit, or refund may be allowed or made if application for a tentative...
IRC Section 409(p) and S Corporation ESOPsBrian D. HectorJason C. Ray
However, the tenure of the CEO significantly increases the likelihood of permitting a Section 83(b) election. Research limitations/implications – This study is limited in the sense that it only examines the year 2004 and the results may be unique to that year. An extension of this study to...
Section 678Grantor TrustIncome TaxThis article explores Section 678 of the Internal Revenue Code and how and when a beneficiary is deemed to be the owner of a trust for income tax purposes (calldoi:10.2139/ssrn.3165592Morrow, Edwin PSocial Science Electronic Publishing...
IRC Section 1031 Tax-Deferred ExchangesInternational Red CrossTax-deferred ExchangesAbilitiesTaxesGainsIntermediariesSellersReplacementUsing Tenancy-in-Common Interests as Replacement PropertyMaples, LarryCaldwell, Charles WWood, Bob G., J...
WhitakerG. Warren
Private Letter Ruling Issued Addressing the Public Benefit Exception Under IRC Section 118(b) Relating to Contributions in Aid of ConstructionMartha Groves PughPhilip Tingle
Section 165(c)(2) deductions also frequently prompt IRS oversight, and in many instances, the standard tax preparation software does not adequately address this deduction, since it's generally geared to the more familiar section 1211 capital loss treatment. But while section 1211 is an appropriate...