Aug 25, 2011 – Such determination is made without regard to §1.1502–1(f)(4 .

[sections] 1.1502-6). [The following section is part of "Representations and .

160+ items – Title 26--Internal Revenue. CHAPTER I--INTERNAL REVENUE .

Unified Agenda 1545-BH20. Amending Section 1.1502-13(c)(6)(ii)(C). Unified Agenda current as of Fall 2010. Twitter · Facebook · Reddit · Digg. Summary .

Mar 3, 2011 – The new rule was intended to provide clarity and avoid requiring the IRS to exercise its discretion under Reg. section 1.1502-13(c)(6)(ii)(C). .

Mar 1, 2003 – 1.1502-6 expressly provides that each group member is severally liable for the group's tax. Additionally, under Regs. Sec. 1.1502-11 (a) (2) and .

1.1502-6(b), 1.1502-77(b). In addition, the Fund asserts that treating Fuqua as subject to contingent withdrawal liability after the 1980 spin-off parallels the .

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Mar 20, 2006 – See, for example, section 1.1502-6, which generally provides that the common parent corporation and each subsidiary that was a member of .

May 25, 2011 – 6 - 1. Whether Section 1.1502-14(d)(4) Operates Solely as .

Jun 1, 1998 – 11 1.1 502-6(a) 108(a) 1.1 502-13(g)(3)(ii)(B)(2) 108(e)(6) 1.1 502-13(g)(3)(i)(A) 165(g)(3) 1.1502-80(c) 165(g)(3) 1.1502-20 304 1.1 502-80(b) .

. is a member of a controlled group of corporations described in paragraph (a)(2 ), (a)(3)(i), or (a)(4) of this section and to which § 1.1502-47(f)(6) does not apply. .

May 10, 2005 – Treasury Regulations, Subchapter A, Sec. 1.1502-6. From TaxAlmanac, A Free Online Resource for Tax Professionals. Note: You are using this .

1.1502-6 for Taxes of the affiliated group of which Parent is the common parent. . 1.1502-6 applies to Company and its Subsidiaries where a section 338(h)(10) .

Such determination is made without regard to §1.1502–1(f)(4) or 1.1502–6(a). ( For inclusion of a successor in references to a subsidiary or member, see .

Jul 5, 2000 – 1.1502-13(f)(6)(ii). The Revenue Ruling is rendered obsolete by the new Regulations, and Reg. 1.1502-13(f)(6)(ii) is rendered superfluous for .

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Oct 6, 2003 – A commentator, who raised questions regarding comparable liability under § 1.1502-6 in such cases, in particular with respect to the interest .

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Section 1.1502-6 - Liability for tax. Date Mouse over help for Date says The .

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(b) Treasury Regulations Sections 1.1502-6 and 1.1502-77. USOP shall be liable for and shall indemnify, defend and hold each of the Spin-Off Companies .

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The election described in paragraph (f)(6)(i)(C)(1) of §1.1502–13 must be made in a separate statement entitled, “ELECTION TO REDUCE BASIS OF P STOCK .

Jun 1, 1997 – Section 1.1502-6 (fn. 231). Moreover, if a corporation ceases to be a member of the group it nevertheless remains liable for all the taxes of the .

May 10, 2005 – 1.1502-5 Estimated tax · Sec. 1.1502-6 Liability for tax · Sec. 1.1502-9 Consolidated overall foreign losses and separate limitation losses .

Aug 15, 2011 – The definitions and nomenclature contained in §1.358–6 apply to this . . in its S stock is increased under §1.1502–32(b) by S 's $10 gain. .

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Jun 1, 1995 – 1.338(h)(10)-1(e)(5) and 1.1502-6(a)). The common parent of the consolidated group is generally treated as the group's agent for Federal .

Section 1.1502-6; provided, however, that such Member shall not be entitled to indemnification by Parent pursuant to this paragraph 5 unless such Member has .

65 results – C.F.R. § 1.1502-6 · AGREEMENT AND PLAN OF MERGER - Agreement and Plan of Merger - Free Search. Professional/Commercial; Agreement And Plan Of .

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