The ordinary course of a trade or business exception is inapplicable because the rents are not derived from a trade or business and will therefore be subject to section 1411.
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However, if the rental real estate activities of the real estate professional are not section 162 trades or businesses, the gross income from rents derived from such activity will not be excluded under section 1411(c)(1)(A)(i) by the ordinary course of a trade or business exception.
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Today, there is little inspiration to be found in the office buildings that now cover the East End's historic streets, with the exception of a stray alleyway or two, but the finished product resembles what Warlow and his team imagined.
Now, in the words of a Vedemosti source, a reduction, an extension in schedule, or a simply cancellation of several weapons programs (with the exception of strategic nuclear forces) are being considered, as are staff reductions in the Ministry of Defense and the Ministry of Internal Affairs (though without any cuts to salaries or social programs).
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Without that designation, unless a preparer meets an exemption or exception, he or she may not work.
In enacting the exception, Congress explained that Subpart F is intended to apply to income of a foreign subsidiary that is either passive or easily moveable, and the lack of an exception caused the Congress to be concerned that the Subpart F provisions applied to income that is neither passive nor easily moveable.
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The second is splitting the decision between two or more people, although I can think of a notable exception.
Thus, the Congress believed it is appropriate to provide an exception for income derived in the active conduct of a banking, financing or similar business.
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People have a lot of trouble meeting the real estate trade or business exception to the rule that makes real estate rental per se passive.
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With the exception of large banks, most of listed Chinese A-share SOEs pay no or low dividends.
West Africa has suffered less than the eastern or southern parts of the continent, but Burkina Faso is a woeful exception.
With the lonely exception of Scott Sumner, virtually every libertarian or conservative who has expressed a strong opinion about monetary policy has come down on the side of the inflation hawks.
Not only did Missouri's voters pick the winning candidate in all but one 20th-century presidential election (the exception was 1956), but they did so by margins that were within a point or two of the national margin.
With one exception, each company trades at a 2001 estimated price-to-earnings ratio of 19 or less, and is expected to generate average annual earnings growth of at least 14% over the next three to five years.
There is an exception to this rule: if your spouse is unable to sign a tax return because he or she is serving in a combat zone or is performing qualifying service outside of a combat zone, and you do not have a power of attorney, you may still sign for your spouse.
Start with a key rule: any money or property you receive is presumed taxable unless you can prove it falls into a recognized exception.
Still, the data show a 2 percent overall increase in hate crimes over the previous year, and a rise in each individual category, with one exception: attacks based on ethnic bias or national origin.
He said his policy is never to call as a witness a police officer who has lied in the past, but he said Lee would likely be an exception, because "a street cop doesn't have Dr. Lee's reputation" or his grounding in science.
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Yet until now, with the exception of narcotics, illicit trade has simply not been a priority in international law and treaty making, or in international police work and cooperative law enforcement.
If you are working as a lawyer or an engineer or something like that, your annual threshold for meeting the exception is the greater of 750 hours or the amount of time you spend on your day job.
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The only exception I make for not saying yes to a media interview is when I am booked with a paid training or speech gig.
It will give the government a chance to push through a reform that is more or less cost free and is popular with almost everyone - the exception being specialist libel lawyers.
In a region where four of the five countries (Finland is the exception) are either doubtful about joining the single European currency or certain not to, there is a reluctance to swallow nostrums from abroad.
The exception is the period of the past 15 years or so, when real house prices took off in a few countries.
The exception would be when "a national court has manifestly made an error in its interpretation of the convention", or if the case "raises a serious question about the way the convention is interpreted or applied".
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Believe it or not, those of you who have the type of friends or family (or cultural background) where starting a business from scratch is a legitimate reason to borrow money are the exception and not the rule.
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