Examples of Active Conduct in a sentence
Time for Determining Active Conduct of a Trade or Business The NPRM clarifies that a single QOZ Business may benefit from multiple overlapping or sequential applications of the working capital safe harbor to different infusions of capital.25 Nonetheless, there is some concern that examples in the proposed regulations illustrating overlapping periods could be read to suggest that an active trade or business must exist at the end of the first 31-month period.
Active Conduct Percentage TestThe active conduct percentage test is provided in proposed §1.1297-5(d).
Thus, the truck does not qualify for the GO Zone additional first year depreciation deduction, regardless of the fact that substantially all of the use of the truck is in the GO Zone in 2007 and 2008..02 Active Conduct of a Trade or Business Requirement.
Exclusions from Active Conduct Under §1.1297-5(b)(2), two categories of insurance companies are precluded from meeting the active conduct test.
See further L.P. Lukjanenko, “LoB – Article X (3) of the OECD MC: Active Conduct of a Business”, in D.
The Active Conduct Requirement is another requirement where additional guidance is critical.
Exclusions From Active Conduct Under § 1.1297–5(b)(2), two categories of insurance companies are precluded from meeting the active conduct test.
For example, if an entity engages in the business of leasing property to another under a triple net lease, then it is possible that this entity will not satisfy the Active Conduct Requirement because such activity is not considered to be “active” conduct.
Thus, the truck does not qualify for the GO Zone additional first year depreciation deduction, regardless of the fact that substantially all of the use of the truck is in the GO Zone in 2007 and 2008..02 Active Conduct of a Trade or Busi- ness Requirement.
Lang et al (eds.), Base Erosion and Profit Shifting (BEPS), 145 et seq; L.P. Lukjanenko, “LoB – Article X (3) of the OECD MC: Active Conduct of a Business”, in D.