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  • Part I - Internal Revenue Service
    DRAFTING INFORMATION The principal author of this revenue ruling is Sean W Mullaney of the Office of Associate Chief Counsel (International) For further information regarding this revenue ruling, contact Mr Mullaney at (202) 622-3860 (not a toll-free call)
  • Internal Revenue Bulletin: 2008-31 | Internal Revenue Service
    This revenue ruling provides various prescribed rates for federal income tax purposes for August 2008 (the current month) Table 1 contains the short-term, mid-term, and long-term applicable federal rates (AFR) for the current month for purposes of section 1274 (d) of the Internal Revenue Code
  • IRS Issues Guidance On Interests In Notional Principal Contracts.
    The principal author of this revenue ruling is Sean W Mullaney of the Office of Associate Chief Counsel (International) For further information regarding this revenue ruling, contact Mr Mullaney at (202) 622-3860 (not a toll-free call)
  • Rev. Rul. 2008-31 - ProQuest
    This ruling holds that certain interests in notional principal contracts, the returns on which are calculated by reference to an index based on data from a geographically and numerically broad range of United States real estate, are not United States real property interests under section 897 (c) (1) of the Code
  • Revenue Ruling 2008-31: IRS Rules That A Swap Interest in A . . . - JD Supra
    On June 12, 2008, the Internal Revenue Service (“IRS”) published Revenue Ruling 2008-31, I R B 2008-26 (the “Ruling”), holding that an interest in a notional principal contract that
  • Andrew Mitchel LLC - International Tax Services
    Reg 1 897-1(d)(2)(i) provides that an interest in real property other than solely as a creditor includes a fee ownership, co-ownership, or leasehold interest in real property, a time sharing interest in real property, and a life estate, remainder, or reversionary interest in such real property
  • Revenue Ruling 2008-31: IRS Rules That A Swap Interest In A . . . - Mondaq
    In the Ruling, the IRS holds that an interest in a swap contract whose return is calculated by reference to a broad-based U S real estate index does not constitute a USRPI
  • Restricted Stock in Acquisitions: IRS Provides Much-Needed Guidance
    The ruling holds that subjecting unrestricted stock to a restriction is not a transfer of property; therefore, Sec 83 cannot apply to the conversion This conclusion is consistent with Letter Ruling 200212005, in which the IRS ruled on a similar transaction
  • Revenue Ruling Clarifies Treatment Of Interest Expense Deductions . . .
    The principal author of this revenue ruling is Faith P Colson of the Office of Associate Chief Counsel (Passthroughs Special Industries) For further information regarding this revenue ruling, contact Faith P Colson at (202) 622-3060 (not a toll-free call)
  • IRS Clarifies Application of the Step-Transaction Doctrine
    On May 8, 2008, the IRS issued Rev Rul 2008-25 to clarify the application of the step-transaction doctrine to situations in which an acquiring corporation (P) acquires a target corporation (T) by means of a reverse subsidiary merger followed immediately by a liquidation of T





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