On January 27, 1994, the Internal Revenue Service ("IRS") issued final Treasury regulations (the "OID Regulations") under the original issue discount provisions of the Internal Revenue Code of 1986, as amended (the "Code"), which replaced certain proposed Treasury regu...
as defined in Section 851 of the Internal Revenue Code, real estate investment trusts, as defined in Section 856 of the Internal Revenue Code, real estate mortgage investment conduits, as defined in Section 860D of the Internal Revenue Code, financial asset securitization investment trusts, as def...
They did so in order to preserve under the Internal Revenue Code (IRC) their potential right to deductions but they also considered the $5 million an advance partial payment of the contribution due in March 1985. By March 1985, however, the IRS had still not ruled. The clubs initially ...
If an outside accounting firm determines that receipt of such a lump sum under the Severance Plan would subject the executive officer to tax under Section 4999 of the Internal Revenue Code of 1986, as amended, he or she may elect to receive in lieu of such lump sum, a reduced amount ...
and on adjustments and transformation on the other hand, and realized the stable development in the complex internal and external environment.In 2020, the Company achieved operating revenue of CNY 21.101 billion and net profit attributable to shareholders of the listed company of CNY 7.482 billion. ...
(Note 2) Consolidated Revenue: External customers ¥2,743,805 ¥1,159,939 ¥826,750 ¥ 824,633 ¥2,103,856 ¥809,192 ¥1,373,241 ¥9,841,419 ¥ 7,140 ¥ – ¥9,848,560 Inter-segment 4,515 31,250 6,602 4,717 6,474 696 76 54,334 3,418 (57,752)...
The Internal Revenue Code1 has fossilized a conception of the corporation as a" real entity." 2 It generally treats that entity like any other taxable person, but it presumes that the entity is" the classic profit maximizer in collective form." 3 According to the tax law, a corporationSu...
Some gold mining companies sell forward their gold to a bullion dealer in order to lock in cash-flow for revenue management purposes. The price they receive on delivery of the gold will be that which was agreed to at the time of the initial transaction, equivalent to the spot price plus ...
U.S. HOLDERS If the Warrants are characterized as "options" for United States Federal income tax purposes, then each Warrant should be treated as a "nonequity" option for purposes of Section 1256 of the Internal Revenue Code of 1986, as amended (the "Code"), which...
Holder. In the opinion of Brown & Wood, counsel to the Company, although there is no authority directly dealing with instruments such as the Warrants, a Warrant should be treated as a nonequity option for purposes of Section 1256 of the Internal Revenue Code of 1986...