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For reasons of this paragraph, all associates of a similar affiliated group of firms (in the indicating of portion 1504 of The inner Earnings Code of 1986) submitting a consolidated return shall be treated as one taxpayer.
“(ii) entirely because of situations which, as determined by the Secretary with the Treasury or his delegate, are not within the control of the lessor or lessee.
“(10) For that lessor only: In case the lessor is actually a partnership or a grantor belief, the title, handle, and taxpayer determining variety of the partners or perhaps the beneficiaries, and the district director’s Office environment with which the cash flow tax return of each husband or wife or beneficiary is filed; and
“(ii) the agreement price tag for such units and equipment represents at least fifty percent of the whole cost of this kind of venture.
this kind of property shall be handled as initially put in services not before than the date of such last sale.
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888 will now cut its losses, launching an evaluation that might produce a sale, “controlled exit”, or “other possible strategic transactions” for its American arm.
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(seven) Coordination with nonrevenue guidelines Any reference During this subsection to your provision not contained During this title shall be addressed for uses of the subsection like a reference to this sort of provision as in effect on the day on the enactment of this paragraph.
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