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1 Dec 2012, 5:19 pm by Arina Shulga
"In looking closer at the statutory definition of “commodity pool” it seems that single swap should not turn a private fund into a commodity pool.Title 7 of the US Code Section 1(a)(10) Commodity pool(A) In generalThe term ‘‘commodity pool’’ means any investment trust, syndicate, or similar form of enterprise operated for the purpose of trading in commodity interests, including any—(i) commodity for future delivery, security futures… [read post]
1 Dec 2012, 5:19 pm by Arina Shulga
In looking closer at the statutory definition of “commodity pool” it seems that single swap should not turn a private fund into a commodity pool.Title 7 of the US Code Section 1(a)(10) Commodity pool(A) In generalThe term ‘‘commodity pool’’ means any investment trust, syndicate, or similar form of enterprise operated for the purpose of trading in commodity interests, including any—(i) commodity for future delivery, security futures product,… [read post]
12 Jul 2015, 5:34 pm
They contend that IRS is not a legal entity which can be sued; that if the real party in interest is the United States, it has not waived its sovereign immunity. [read post]
13 Nov 2012, 2:50 pm by michael brennan
Year Exclusion Amount Max/Top tax rate 2001 $675,000 55% 2002 $1 million 50% 2003 $1 million 49% 2004 $1.5 million 48% 2005 $1.5 million 47% 2006 $2 million 46% 2007 $2 million 45% 2008 $2 million 45% 2009 $3.5 million 45% 2010 Repealed 2011 $5 million 35% 2012 $5.12 million 35% 2013* $1 million 55% * under current law Under current law, in 2013 the… [read post]
27 Oct 2018, 1:48 pm by Ettinger Law Firm
Homestead properties are “exempt from application to the satisfaction of a money judgment, unless the judgment was recovered wholly for the purchase price thereof: 1) lot of land with a dwelling thereon, 2) shares of stock in a cooperative apartment corporation, 3) units of a condominium apartment, or 4) a mobile home. [read post]
19 Jul 2022, 7:26 am by Cathy Moran
Thus, the two critical questions are 1) whether the business filed a return (triggering the 3 year assessment period) and 2) when the tax authority (these days known as CDTFA) got knowledge of the termination, dissolution or abandonment of the business. [read post]
5 Sep 2018, 10:20 am by Matthew Landis
Similar to above, Philadelphia imposes an additional use tax of 2% and Allegheny County imposes a 1% additional use tax. [read post]
24 Sep 2014, 3:40 am by Broc Romanek
Internal Revenue Service issued the “check-the-box” Treasury Regulations, providing that (1) entities formed as corporations (and a long list of corresponding non-U.S. entities) would be taxed as corporations (other than certain exceptions such as REITs or S corporations), and (2) other forms of business entities would default to a non-corporate status but could elect to be taxed as a corporation. [read post]
5 Nov 2016, 8:26 am by Charles (Chuck) Rubin
Fla 2012)) Theories expanding fiduciary duties to persons affiliated with owning entities, based on expansive case law, such as In re USACafes, L.P. [read post]
12 Aug 2020, 2:08 pm by Unknown
"Quite frankly I trust the mobility companies to come up with better rules for operation than any government entity. [read post]
13 Jan 2009, 7:58 am
Advantages 1) Platform to combine personal and charitable goals. 2)Current environment attractive to lead trust gifts. 3) Short-term foundation substitute 4)Short-term foundation substitute. 4) • Long-term philanthropy funding mechanism Disadvantages 1) Complex trust tax rates. 2)Prohibited transaction rules apply. 3) Donor involvement limitations when lead trust funds private foundation … [read post]
13 Sep 2019, 10:29 am by Rebecca Tushnet
”  (What happens when a provider says “this entity has produced objectionable content in the past and we are therefore going to screen material from this entity”? [read post]
27 Feb 2017, 5:00 am by Bryston Gallegos
§ 1108(b)(8) if: (1) the transaction involves selling or purchasing fund interests; (2) the trust company is not overcompensated; and (3) the transaction is expressly permitted by an authoritative party. [read post]
7 Apr 2014, 12:24 pm
  They face an uphill battle in the trial court, because Judge Goodstein will follow the law as given by the Supreme Court, according to which (1) ECUSA's Dennis Canon did not automatically create any kind of enforceable trust interest in Episcopal parish property in the State, and (2) South Carolina religious corporations which follow the procedures in their own articles and bylaws may amend those documents in the absence of any restriction on their power to do… [read post]