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None of E's taxes paid in 1982 that are attributable to income earned or received in 1981 are subject to disallowance because, under paragraph (c)(2)(ii) of this section, the only taxes disallowed are those deemed to accrue on income earned and received after December 31 , 1981 and excluded from gross income.
The amount of E's taxes paid to S in 1982 that accrue to 1982 foreign earned income, and are therefore subject to disallowance based on excluded income, is $19,091, or $70,000 × $45,000/$165,000.
The agency lawsuit says Monex International Ltd., run by Louis Carabini, agreed in early 1998 to a court judgment that it owed $134 million for 1980 to 1984, a sum due largely to disallowance of a dodgy tax shelter involving London Metal Exchange straddle transactions.
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The portion of the underpayment attributable to the adjustment unrelated to the disallowance of the NOLCB will be subject to a penalty rate of 25percentt under former section 6661.
See §§ 20.2055-4 and 20.2055-5 foruleses relating to the disallowance of deductions to trusts and organizations which engage in certain prohibited transactions or whose governing instruments do not contain certain specified requirements.
The portion of the underpayment attributable to the disallowance of the NOLCB will be subject to a penalty rate of 20percentt under section 6662.
The plaintiff excepted, by his first and second exceptions, to the disallowance in respect of the 156 copies resold, and filed other exceptions.
When the federal government complied, Brownlee protested its action on three grounds: first, as a direct tax the proposed levy was within Alberta's rights under section 92 of the British North America Act, 1867, and it was constitutional convention for the federal government to exercise disallowance only when the impugned legislation was clearly unconstitutional.
On that occasion the authority to make disallowances was transferred to the Department of the Treasury.
The two largest such rightsholders, the Canadian Pacific Railway and the Hudson's Bay Company, urged the federal government to use its power of disallowance to put a stop to the legislation.
Parliament's return on Tuesday will see the Greens move to disallow the Abbott government's temporary protection visas, and force greater transparency over the reporting of operations at sea. Labor has hinted it could support the disallowance of TPVs – although internal views are mixed and no decision has been made.
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Justyna Jupowicz-Kozak
CEO of Professional Science Editing for Scientists @ prosciediting.com