Putting It All Together
TD 9636 has well over 100 case studies and examples included throughout the text. While the IRS won’t ‘draw a line in the sand’, they do give some pretty concrete samples of differing scenarios. Reg. Section 1.263(a) also has numerous examples for you to use when deciding how to best serve your client.
To summarize everything and put it all together, the following are the items that apply to all of the safe harbors we have discussed:
1. The company must have a written policy, in place before the beginning of the tax year in question, setting the non-tax related reasons for the use of the safe harbor. Read More
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