Common use of Specific descriptions of issues Clause in Contracts

Specific descriptions of issues. A request for a PFA should also contain a separate written statement for each proposed issue that concisely: (1) Describes the issue; (2) Summarizes all the facts that are relevant and material to the issue and, in the case of agreements for future taxable years, any related factual assumptions that may be appropriate (see section 7.02(2), below); (3) States whether the issue involves an item or transaction in which two or more persons may take contrary positions (a “whipsaw” issue); (4) Summarizes all relevant legal authorities, including citations to specific sections of the Internal Revenue Code, Income Tax Regulations, case law, tax treaties, and other authorities, and discusses why the issue is an eligible issue, as defined in section 3 of this revenue procedure; (5) Xxxxxxxxxx and discusses the implications of any known authorities that may be potentially contrary to the position advanced, such as legislation (or pending legislation), court decisions, regulations, revenue rulings, revenue procedures, notices (including notices of proposed rulemaking), or announcements; (6) Discusses whether and how the PFA will affect taxable years before or after the taxable year for which the PFA is sought; (7) Describes any proposed methodology to be used; (8) Discusses whether the issue qualifies for mutual agreement procedure consideration under any United States income tax treaty, specifies the treaty, and states whether the taxpayer previously applied or will apply for competent authority assistance with respect to the issue for the year or years in question or any prior year; (9) States whether the taxpayer has, for the current taxable year or any prior taxable year, requested a private letter ruling (including a request for consent to a change in method of accounting or a request to adopt, change, or retain an annual accounting period), determination letter, or technical advice on the issue; (10) Discusses whether the issue can reasonably be resolved by the earliest date on which the taxpayer intends to file any relevant return; and (11) Describes the availability, organization, and location of the records and other information that substantiate the taxpayer's proposed position on the issue.

Specific descriptions of issues. A request for a PFA should also contain a separate written statement for each proposed issue that concisely: (1) Describes the issue; (2) Summarizes all the facts that are relevant and material to the issue and, in the case of agreements for future taxable years, any related factual assumptions that may be appropriate (see See section 7.02(2), below); (3) States whether the issue involves an item or transaction in which two or more persons may take contrary positions (a “whipsaw” issue); (4) Summarizes all relevant legal authorities, including citations to specific sections of the Internal Revenue Code, Income Tax Regulationsincome tax regulations, case law, tax treaties, and other authorities, and discusses why the issue is an eligible issue, as defined in section 3 of this revenue procedure; (5) Xxxxxxxxxx and discusses the implications of any known authorities that may be potentially contrary to the position advanced, such as legislation (or pending legislation), court decisions, regulations, revenue rulings, revenue procedures, notices (including notices of proposed rulemaking), or announcements; (6) Discusses whether and how the PFA will affect taxable years before or after the taxable year for which the PFA is sought; (7) Describes any proposed methodology to be used; (8) Discusses whether the issue qualifies for mutual agreement procedure consideration under any United States income tax treaty, specifies the treaty, and states whether the taxpayer previously applied applied, or will apply apply, for competent authority assistance with respect to the issue for the year or years in question or any prior year; (9) States whether the taxpayer has, for the current taxable year or any prior taxable year, requested a private letter ruling (including a request for consent to a change in method of accounting or a request to adopt, change, or retain an annual accounting period), determination letter, or technical advice on the issue; (10) Discusses whether the issue can reasonably be resolved by the earliest date on which the taxpayer intends to file any relevant tax return; and (11) Describes the availability, organization, and location of the records and other information that substantiate the taxpayer's proposed position on the issue.

Specific descriptions of issues. A request re- quest for a PFA should also contain a separate sep- arate written statement for each proposed issue that concisely: (1) Describes the issue; (2) Summarizes all the facts that are relevant and material to the issue and, in the case of agreements for future taxable years, any related factual assumptions that may be appropriate (see section 7.02(2), below); (3) States whether the issue involves an item or transaction in which two or more persons may take contrary positions (a “whipsaw” issue); (4) Summarizes all relevant legal authoritiesau- thorities, including citations to specific sections of the Internal Revenue Code, Income Tax Regulations, case law, tax treaties, and other authorities, and discusses dis- cusses why the issue is an eligible issue, as defined in section 3 of this revenue procedure; (5) Xxxxxxxxxx and discusses the implications im- plications of any known authorities that may be potentially contrary to the position advanced, such as legislation (or pending legislation), court decisions, regulations, revenue rulings, revenue procedures, notices no- tices (including notices of proposed rulemakingrule- making), or announcements; (6) Discusses whether and how the PFA will affect taxable years before or after the taxable year for which the PFA is sought; (7) Describes any proposed methodology methodol- ogy to be used; (8) Discusses whether the issue qualifies quali- fies for mutual agreement procedure consideration con- sideration under any United States income tax treaty, specifies the treaty, and states whether the taxpayer previously applied or will apply for competent authority assistance assis- tance with respect to the issue for the year or years in question or any prior year; (9) States whether the taxpayer has, for the current taxable year or any prior taxable tax- able year, requested a private letter ruling rul- ing (including a request for consent to a change in method of accounting or a request re- quest to adopt, change, or retain an annual an- nual accounting period), determination letterlet- ter, or technical advice on the issue; (10) Discusses whether the issue can reasonably be resolved by the earliest date on which the taxpayer intends to file any relevant return; and (11) Describes the availability, organizationorgan- ization, and location of the records and other information that substantiate the taxpayer's tax- payer’s proposed position on the issue.

Specific descriptions of issues. A request for a PFA should also contain a separate written statement for each proposed issue that concisely: (1) Describes the issue; (2) Summarizes all the facts that are relevant and material to the issue and, in the case of agreements for future taxable years, any related factual assumptions that may be appropriate (see section 7.02(2), below); (3) States whether the issue involves an item or transaction in which two or more persons may take contrary positions (a “whipsaw” issue); (4) Summarizes all relevant legal authorities, including citations to specific sections of the Internal Revenue Code, Income Tax Regulations, case law, tax treaties, and other authorities, and discusses why the issue is an eligible issue, as defined in section 3 of this revenue procedure; (5) Xxxxxxxxxx and discusses the implications of any known authorities that may be potentially contrary to the position advanced, such as legislation (or pending legislation), court decisions, regulations, revenue rulings, revenue procedures, notices (including notices of proposed rulemaking), or announcements; (6) Discusses whether and how the PFA will affect taxable years before or after the taxable year for which the PFA is sought; (7) Describes any proposed methodology to be used; (8) Discusses whether the issue qualifies for mutual agreement procedure consideration under any United States income tax treaty, specifies the treaty, and states whether the taxpayer previously applied or will apply for competent authority assistance with respect to the issue for the year or years in question or any prior year; (9) States whether the taxpayer has, for the current taxable year or any prior taxable year, requested a private letter ruling (including a request for consent to a change in method of accounting or a request to adopt, change, or retain an annual accounting period), determination letter, or technical advice on the issue; (10) Discusses whether the issue can reasonably be resolved by the earliest date on which the taxpayer intends to file any relevant return; and (11) Describes the availability, organization, and location of the records and other information that substantiate the taxpayer's proposed position on the issue.

Specific descriptions of issues. A request for a an LMSB PFA should also contain a separate written statement for each proposed issue that concisely: (1) Describes the issue; (2) Summarizes all the facts that are relevant and material to the issue and, in the case of agreements for future taxable years, any related factual assumptions that may be appropriate (see section 7.02(2), below)issue; (3) States whether the issue involves an item or transaction in which two or more persons may take contrary positions with respect to the item or transaction (a “whipsaw” issue); (4) Summarizes all relevant legal authorities, including citations to specific sections of the Internal Revenue Code, Income Tax Regulations, case law, tax treaties, law and other authorities, and discusses why the issue is an eligible issue, issue as defined in section 3 of this revenue procedure; (5) Xxxxxxxxxx and discusses the implications of any known authorities that may be potentially contrary to the position advanced, such as legislation (or pending legislation), tax treaties, court decisions, regulations, revenue rulings, revenue procedures, notices (including notices of proposed rulemaking)notices, or announcements; (6) Discusses the suitability of the issue for the LMSB PFA program in light of the purpose and criteria set forth in sections 1, 2, and 3 of this revenue procedure; (7) Discusses whether and how the LMSB PFA will affect have any effect in taxable years periods either before or after the taxable year period for which the LMSB PFA is sought; (7) Describes any proposed methodology to be used; (8) Discusses whether the issue qualifies for mutual agreement procedure consideration under any United States income tax treaty, specifies the treaty, and states whether the taxpayer previously has applied or will apply for competent authority assistance with respect to the issue for the year or years in question or any prior year; (9) States whether the taxpayer hasissue, for the current taxable year or any prior taxable yearpart of the issue, requested a private letter ruling (including has ever been the subject of a request for consent to a change in method of accounting or a request to adopt, change, or retain an annual accounting period)private letter ruling, determination letter, consent to change a method of accounting, or technical advice on with respect to the issueyear in question or any prior year; (10) Discusses whether the issue can reasonably be resolved by the earliest date on which the taxpayer intends to file any relevant returnits return for the taxable period in question; and (11) Describes the availability, organization, organization and location of the records and other information evidence that substantiate the taxpayer's proposed position on the issue.