An anomaly described in a recent IRS ruling says there is a big, but subtle, difference. Robert Willens, CFO.com | US. February 20, 2008. A fine line exists between definitions of a corporate liquidation and dissolution. But for tax purposes, the defining line can make a big difference. Witness the situation described in recent letter from the Internal Revenue Service (LTR 200806006, November 7, 2007), which addresses a seeming anomaly related to the tax code. The anomaly is corporate dissolution without liquidation.
a person with the ability or power to use, control, or dispose of something: a master of six languages; to be master of one's fate. 2. an owner of a slave, animal, etc. 3. an employer of workers or servants. 4. the male head of a household.
The master agreement is a document agreed between two parties that sets out standard terms that apply to all the transactions entered into between those parties. Each time that a transaction is entered into, the terms of the master agreement do not need to be re-negotiated and apply automatically.Although it is often viewed as a tool for banks and financial institutions, the Master Agreement is widely used by a wide variety of counterparties.ection 2(d) of the ISDA Master Agreement contains provisions setting out the consequences if a tax is imposed on a payment required to be made by a party under a transaction. Included is a gross-up obligation for certain Indemnifiable Taxes.