Please read this:

randucci said:
The key is to always stay behind the UBERHOG to find out where the good stuff is, then cut in front for the kill :eek:
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That's some good advice! "NO REGRETS" right? :D

Good post Bryan :thumbup: I've been very lucky in my short time here. Had great help from some of the "old timers", yourself included. Thank you to all those that have helped me along the way!
 
Resin,

Why don't you mix up some glue for him?

You can tell me what you want and I'll pick it up.

It's safer that way, I don't know much about chemistry.
 
Personally, I plan to arrive at Blade an unspecified number of days early with a tent.

If it can work for Star Wars tickets....

EDIT: In response to Wash (Samurai Poster) -- well, I thought the bottles went without saying! A man cannot live by tent alone.
 
Tony G said:
First question on the application:

Do you think that a minority interest (publicly traded on a US exchange) prevents a majority interest foreign owner from being considered to have "control" of a US Corporation as "control" is described under section 482 of the Internal Revenue code? :o

P.S. I do not expect a reply but it is an interesting question.
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Tony,
Your question is slightly unclear. Are you asking if a domestic third party having a minoty interest is sufficient to prevent the control relationship of the foreign-owned majority? If so, I'll be right back to you.
 
smokelaw1 said:
Tony,
Your question is slightly unclear. Are you asking if a domestic third party having a minoty interest is sufficient to prevent the control relationship of the foreign-owned majority? If so, I'll be right back to you.
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No widely held and traded on a major US exchange.

Again I don’t expect an answer, it is just an interesting question.

Actually that was an old problem I worked on and it ended up getting settled. I always wondered what the right answer was. We couldn’t come up with a strong answer and it wasn’t huge money so the client decided to settle.

 
Tony G said:
First question on the application:

Do you think that a minority interest (publicly traded on a US exchange) prevents a majority interest foreign owner from being considered to have "control" of a US Corporation as "control" is described under section 482 of the Internal Revenue code?
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For those of you wondering just what §482 says................

"26 U.S.C.A. § 482

I.R.C. § 482

United States Code Annotated Currentness

Title 26. Internal Revenue Code (Refs & Annos)

Subtitle A. Income Taxes (Refs & Annos)

Chapter 1. Normal Taxes and Surtaxes (Refs & Annos)

Subchapter E. Accounting Periods and Methods of Accounting

Part III. Adjustments

§ 482. Allocation of income and deductions among taxpayers

In any case of two or more organizations, trades, or businesses (whether or not incorporated, whether or not organized in the United States, and whether or not affiliated) owned or controlled directly or indirectly by the same interests, the Secretary may distribute, apportion, or allocate gross income, deductions, credits, or allowances between or among such organizations, trades, or businesses, if he determines that such distribution, apportionment, or allocation is necessary in order to prevent evasion of taxes or clearly to reflect the income of any of such organizations, trades, or businesses. In the case of any transfer (or license) of intangible property (within the meaning of section 936(h)(3)(B)), the income with respect to such transfer or license shall be commensurate with the income attributable to the intangible.

Current through P.L. 109-482 (End) approved 01-15-07

Copr. © 2007 Thomson/West. No Claim to Orig. U.S. Govt. Works.

END OF DOCUMENT"


I have no idea what it means because I never got a J.D. :confused:
 
RVO3VOM said:
For those of you wondering just what §482 says................

"26 U.S.C.A. § 482

I.R.C. § 482

I have no idea what it means because I never got a J.D. :confused:
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Yes that one sentence must keep thousands of tax lawyers, economist and accountants employed world wide.
Edit.. it has been amended to two now.
 
wash said:
I don't know what Jaxx is talking about.

I was happy that I got a pair of SOW's, #7 and 8 by Amy's count. Then I hear that Jaxx got 6 SOW's. I bet they were #1-6.

I thought I had finally out done him when he was having trouble with the Fire Warden, but he got his.

I don't know how I'll beat him to the trough.

I'm working on a diversionary tactic for the Blade show.
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ACTUALLY... I got beat by only ONE person (Yes, I asked) ...So I guess that I got #'s 2-7!!!!! ...Coincidence??? ;) :D :D :D :thumbup::thumbup:
 
idahoskunk said:
BURN HER!!!!
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gallery_2_1_88797.jpg
 
THAT is a cosmic question.

Are there any coincidences? Einstein would suggest...no. But Heisenberg and Schroedinger would say...yes.

I'm of two minds.
 
I got #7, Amy told me so.

You must have at least one fake out of the six.

Just send them to me and I'll sort it all out.
 
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