Charitable sports promotion: sponsorship receipts alone did not defeat registration where funds supported tournaments and player development activitie...
Overdue associated-enterprise receivables: debt-free status defeated notional-interest adjustment, while employee stock-option costs qualified as busi...
Retrospective assessment-limitation amendments validate final orders while contemporaneous segment data governs transfer-pricing comparability and tol...
Transfer pricing adjustments must track international transactions, while unsupported AMP adjustments and unsuitable manufacturing comparables require...
Transfer-pricing adjustments must reflect functional comparability, working-capital effects, and avoid duplicating interest on associated-enterprise r...
Provisional attachment of properties acquired from proceeds of crime may be sustained despite asserted prior sales, partial sales, or mortgages where recipients of funds from an accused entity cannot establish genuine business activity or an independent source for acquiring the properties. Properties traced to tainted funds through entities controlled by the accused remain subject to attachment. A person who has already sold a property has no subsisting interest to challenge its attachment; any purchaser may pursue an independent remedy. Mortgages do not by themselves require release of attached property, while any valid independent claim of a financial institution or other third party remains open.
Provisional attachment of properties acquired from proceeds of crime may be sustained despite asserted prior sales, partial sales, or mortgages where recipients of funds from an accused entity cannot establish genuine business activity or an independent source for acquiring the properties. Properties traced to tainted funds through entities controlled by the accused remain subject to attachment. A person who has already sold a property has no subsisting interest to challenge its attachment; any purchaser may pursue an independent remedy. Mortgages do not by themselves require release of attached property, while any valid independent claim of a financial institution or other third party remains open.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4888 
