Voorbeeld van arbitrageovereenkomst
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Zakelijk Wettelijk wil partijen Arbitrage voorbeeld arbitrageovereenkomst Arbiter Wat is een arbitrageovereenkomst? Belastingbetaler
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c) With respect to the Electing Taxpayer or an entity that was a member of the Electing Taxpayer’s consolidated group (including any successor to such group) at any time, the manner and timing of the reduction in the tax benefits necessary to eliminate any duplication in the tax benefits associated with the Contingent Liability Transaction in amounts that, in the aggregate, equal the capital loss permitted under (a) above.. Members or employees of the Arbitrator’s firm will also be disqualified from representing the Electing Taxpayer or any other parties involved in the transactions or issues that are the particular subject matter of the arbitration in an action that involves the transactions or issues that are the particular subject matter of the arbitration, unless: (i) the Arbitrator disclosed the potential of such representation prior to the parties’ acceptance of the Arbitrator (ii) such action relates to a taxable year that is different from the taxable year(s) under arbitration (iii) the firm’s internal controls preclude the Arbitrator from any form of participation in the matter and (iv) the firm does not allocate to the Arbitrator any part of the fee therefrom.. The Parties agree that only the following issue will be submitted to the Arbitrator: Which of the two Final Offers presented by the Parties best reflects the hazards of litigating the Taxpayer’s entitlement to a capital loss deduction from the sale of stock received as part of the Contingent Liability Transaction In reaching a determination on the issue submitted, the Arbitrator may only consider the legal and factual arguments made in the Fast Track Dispute Resolution Procedure - Contingent Liability Cases, including the facts developed under Section 7.02 of Rev.. Service and Treasury employees who participate in any way in the arbitration process and any person under contract to the Service pursuant to section 6103(n) of the Internal Revenue Code of 1986, as amended, including the Arbitrator, tha
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