Ibf fund liquidating llc tax information


30-Mar-2019 00:04

“Surviving spouse” shall have the same meaning as provided in section 2(a) of the Internal Revenue Code of 1986; except, that in applying section 2(a) of the Internal Revenue Code of 1986, the term spouse shall be deemed to include a domestic partner. “State” means any state of the United States, the District of Columbia, the Commonwealth of Puerto Rico, any territory, or possession of the United States and any foreign country or political subdivision thereof.

ibf fund liquidating llc tax information-7

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For a particular tax year in question has no, or nominal, effective tax on the relevant income and has laws or practices that prevent effective exchange of information for tax purposes with other governments regarding taxpayers benefitting from the tax regime; Lacks transparency, which, for the purposes of this definition, means that the details of legislative, legal, or administrative provisions are not open to public scrutiny and apparent or are not consistently applied among similarly situated taxpayers; Explicitly or implicitly excludes the jurisdiction’s resident taxpayers from taking advantage of the tax regime’s benefits or prohibits enterprises that benefit from the regime from operating in the jurisdiction’s domestic market; or Has created a tax regime that is favorable for tax avoidance, based upon an overall assessment of relevant factors, including whether the jurisdiction has a significant untaxed offshore financial or other services sector relative to its overall economy. 146, title IV, §§ 401, 402; March 31, 1956, 70 Stat. “Employee” means an individual having a place of abode or residing or domiciled within the District at the time the tax is required to be withheld in respect to the individual’s employment by another, and to every other individual who maintains a place of abode within the District for an aggregate of 183 days or more during the taxable year, whether domiciled in the District or not, including an officer of a corporation, but excluding any elective officer of the government of the United States or any officer or employee in the legislative branch of the government of the United States whose compensation is paid by the Secretary of the Senate or Clerk of the House of Representatives, any officer of the executive branch of the government of the United States whose appointment was made by the President of the United States, subject to confirmation by the Senate of the United States, and whose tenure of office is at the pleasure of the President of the United States, or any Justice of the Supreme Court of the United States, unless the officer, employee, or justice is domiciled within the District of Columbia at any time during the taxable year. “Dividend” means any distribution made by a corporation or financial institution (domestic or foreign) to its stockholders or members, out of its earnings, profits, or surplus, other than paid-in surplus, whenever earned by the corporation or financial institution and whether made in cash or in any other property (other than stock of the same class in the corporation or financial institution, if the recipient of the stock dividend has neither received nor exercised an option to receive the dividend in cash or in property other than stock instead of stock) and whether distributed before, during, upon, or after liquidation or dissolution of the corporation or financial institution; except, that in the case of any such distribution, any part of which for purposes of the income tax imposed under the Internal Revenue Code of 1986 is deemed to constitute a capital gain, such part shall be deemed to constitute a capital gain for purposes of the tax imposed by this chapter; provided, that in the case of any dividend that is distributed other than in cash or stock in the same class in the corporation or financial institution and not exempted from tax under this chapter, the basis of tax to the recipient shall be the market value of the property at the time of the distribution; provided further, that a dividend shall not include any dividend paid by a mutual life insurance company to its shareholders. For taxable years beginning before January 1, 2015, the amount of ,000 increased annually by the cost-of-living adjustment (if the adjustment does not result in a multiple of , rounded to the next lowest multiple of ) for a single individual and one-half of the amount that may be taken by a single individual for a married individual filing a separate return; For taxable years beginning after December 31, 2014, but before January 1, 2017, ,200 increased annually by the cost-of-living adjustment (if the adjustment does not result in a multiple of , rounded to the next lowest multiple of ); For taxable years beginning after December 31, 2016, but before January 1, 2018, ,650 increased annually by the cost-of-living adjustment (if the adjustment does not result in a multiple of , rounded to the next lowest multiple of ); or For taxable years beginning before January 1, 2015, the amount of ,000 increased annually by the cost-of-living adjustment (if the adjustment does not result in a multiple of , rounded to the next lowest multiple of ); For taxable years beginning after December 31, 2014, but before January 1, 2017, ,500 increased annually by the cost-of-living adjustment (if the adjustment does not result in a multiple of , rounded to the next lowest multiple of ); For taxable years beginning after December 31, 2016, but before January 1, 2018, ,800 increased annually by the cost-of-living adjustment (if the adjustment does not result in a multiple of , rounded to the next lowest multiple of ); or For taxable years beginning before January 1, 2015, the amount of ,000 increased annually by the cost-of-living adjustment (if the adjustment does not result in a multiple of , rounded to the next lowest multiple of ); For taxable years beginning after December 31, 2014, but before January 1, 2017, ,350 increased annually by the cost-of-living adjustment (if the adjustment does not result in a multiple of , rounded to the next lowest multiple of ); For taxable years beginning after December 31, 2016, but before January 1, 2018, ,275 increased annually by the cost-of-living adjustment (if the adjustment does not result in a multiple of , rounded to the next lowest multiple of ); or In the case of an individual who is a resident, as defined in paragraph (42) of this section, for less than a full 12-month taxable year, the amounts specified in subparagraph (A), (B), or (C) of this paragraph prorated by the number of months that the individual was a resident.

The term “sales” does not include receipts of a taxpayer from hedging transactions and from the maturity, redemption, sales, exchange, loan, or other disposition of cash or securities.

For purposes of combined reporting, The term “person” shall not include a Qualified High Technology Company as defined in § 47-1817.01(5)(A).