and Prop Sample Clauses

and Prop. Treas. Reg. §1.415(c)-2(d)(2)). Code §415 Compensation means the Employee's wages, salaries, fees for professional service and other amounts received (without regard to whether or not an amount is paid in cash) for personal services actually rendered in the course of employment with the Employer maintaining the Plan to the extent that the amounts are includible in gross income (including, but not limited to, commissions paid salespersons, compensation for services on the basis of a percentage of profits, commissions on insurance premiums, tips, bonuses, fringe benefits and reimbursements or other expense allowances under a nonaccountable plan as described in Treas. Reg. §1.62-2(c)). Code §415 Compensation does not include:

and Prop. Treas. Reg. §1.415(c)-2(a). Under this definition, Compensation means as defined in Section 1.11(B)(3) but with the addition of: (a) amounts described in Code §§104(a)(3), 105(a), or 105(h) but only to the extent that these amounts are includible in Employee's gross income; (b) amounts paid or reimbursed by the Employer for moving expenses incurred by the Employee, but only to the extent that at the time of payment it is reasonable to believe these amounts are not deductible by the Employee under Code §217; (c) the value of a nonstatutory option (an option other than a statutory option under Treas. Reg. §1.421-1(b)) granted by the Employer to the an Employee, but only to the extent that the value of the option is includible in the Employee's gross income for the Taxable Year of the grant; and (d) the amount includible in the Employee's gross income upon the Employee's making of an election under Code §83(b). The Employer in Appendix B also must elect whether to include as Compensation amounts received from a nonqualified unfunded deferred compensation plan in the Taxable Year received but only to extent includible in gross income.

and Prop. Reg. Sec.

and Prop. Reg. ss.1.368-2(m)(3)(ii), each of the Transactions, being a simple redomestication, will qualify as a reorganization under Section 368(a)(1)(F), notwithstanding the subsequent step. In this regard, we note that the Transactions would have been entered into regardless of the Allegiant/PNC Reorganizations. Indeed, redomestication transactions are occurring for some other Allegiant Funds that are not involved in the Allegiant/PNC Reorganizations at all. This provides evidence that the Transactions and the Allegiant/PNC Reorganizations are not integrated, interdependent, or focused toward a particular end result and, thus, further supports the conclusion that the step-transaction doctrine should not be applied to treat the Transactions and the Allegiant/PNC Reorganizations as combined transactions for Federal income tax purposes

and Prop. 3.11 that Xxxxxx’s description of Xxxxxxxxx’s death ‘challenges Xxxxxxxx propaganda’, and that Xxxxxxxxxx ‘went out of his way to advertise that his Cleopatra portrait conformed with the official, hostile Xxxxxxxx version.’ Xxxxxxxxx’s excessive drinking was one of the general Roman invectives against her directed at the good sober Roman way of living versus the licentious customs of the other. Although the Ptolemaic court may have been known for its abuse of wine, it is also plausible that the image of Xxxxxxxxx as a drunk is created because of her affiliation with Xxxx Xxxxxx, who famously had to apologize for his alcohol abuse in his tractate, De ebrietate sua. The specific association between Xxxxxxxxx and drunkenness may also have been created extra Xxxx Xxxxxx as a Greek epigram linking Xxxxxxxxx to the figure of [méthee, Greek], possibly referring to méthee nephalios: ‘divine joy of life’. For the probable impossibility that the Augustan connections between Xxxxxxxxx and drunkenness are ‘a willful misinterpretation of this symbol’, see Xxxxxx and Xxxxxxx 1970, 414-415, also for the quotes and further references. Other reference to alcohol abuse at the Ptolemaic court under Xxxxxxxxx include: Prop. 3.11.55-56; Hor. Carm. 1.37.14; Strabo 17.1.11; Luc. BC 10.161-163. For Xxxx Xxxxxx’x apology, see Xxx. Epist. 83.25; Plin. NH 14.148. For anecdotes concerning Xxxxxx’s licentiousness, see e.g.