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by treating it as net unrecognized section 987 gain or loss of the relevant section 987 QBU. In order to expeditiously conduct an examination (including any related administrative appeal) of a tax-exempt bond issue, an issuer is generally treated as the taxpayer on behalf of any unidentified beneficial owners of the bonds comprising the issue under examination. Attribution of items to an eligible QBU. "Mengniu Group added to Fifa World Cup sponsor line-up".
X contributes 50 of its Business A assets and liabilities to coastal eyewear coupon Z in exchange for 100 of the stock. (5) Step 5: Increase the aggregate amount determined in steps 1 through 4 by amount of liabilities transferred from the owner to the section 987 QBU. (d) Items of income, gain, deduction or loss that are denominated in a nonfunctional currency (other than the functional currency of the owner). The facts are the same as in Example 1 except that French DE sold raw land on November 1, 2009 for 10,000. (3) Section 987 historic asset. This amount shall include amounts appropriately considered as net unrecognized exchange gain or loss under the transition rules.987-10.