SA gives aid to storm-hit Madagascar

first_img14 March 2012 South Africa handed over humanitarian aid to Madagascar on Tuesday to help the island nation recover from the devastation caused by the recent cyclone Giovanna and tropical storm Irina. Led by Deputy Minister of International Relations and Cooperation, Marius Fransman, the South African mission saw several aid organisations contributing and pledging aid and assistance to Madagascar. These include the Al-Imdaad Foundation, which contributed aid worth US$100 000 in the form of blankets, water-purification tablets, tents and food hampers, as well as Netcare, which assisted with logistical arrangements. The Norwegian Government contributed to the humanitarian project by making the transportation of the aid to Madagascar possible. The two tropical disturbances which hit Madagascar last week killed at least 111 people and left 332 204 people homeless, according to the National Office of Risks and Disasters Management. The highest number of deaths recorded after the passage of Irina was in Ifanadiana district in the southeast of the island country, with 48 reported dead; while Vangaindrano and Farafangana districts, also in the southeast, recorded the most homeless people, with 3 909 and 25 086 respectively. Nearly 7 056 housing spaces were flooded, 147 were damaged and 1 372 were completely destroyed by Irina, while 3 713 hectares of rice fields and 12 600 crop fields were affected. The data was collected from 103 of the 829 municipalities in the trajectory of Irina. Cyclone Geralda, which swept through the island country in February 1994, was the last cyclone category 4 before Giovanna. Geralda killed 231 people. Last year, Cyclone Bingiza killed at least 34 people and left 216 000 homeless. In 2010, tropical storm Hubert killed at least 83 people and left nearly 187 000 homeless. Madagascar enters in the cyclone season from 15 November to 30 April of each year. Whilst in Madagascar, Fransman – who is also chair of the SADC Organ Troika and serves as President Jacob Zuma’s special envoy on Madagascar – was expected to meet with the Malagasy stakeholders to address certain outstanding aspects pertaining to the full implementation of the SADC roadmap aimed at restoring political stability to the island nation. Source: BuaNews-Xinhualast_img read more

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FPAA Statute of Limitations Barred Assessment of Tax on LLC Taxed as Partnership (DTDV, LLC, TCM)

first_imgLogin to read more tax news on CCH® AnswerConnect or CCH® Intelliconnect®.Not a subscriber? Sign up for a free trial or contact us for a representative. The statute of  limitations barred a tax assessment on an LLC taxed as a partnership. Any shift in gain from a limited liability company (LLC) classified as a partnership for federal tax purposes to a foreign entity (FE) that might violate the assignment of income doctrine did not justify altogether disregarding FE’s interest in LLC. FE was formed to hold segregated account investment services in support of an insurance policy on the life of LLC’s tax matter partner (TMP). Because TMP’s transfer to FE of an interest in LLC is respected for federal tax purposes, LLC made a valid Code Sec. 754 election in connection with that transfer. In turn, because of the resulting Code Sec. 743(b) basis adjustment, LLC did not omit from gross income an amount in excess of 25 percent of its reported gross income.Tax Assessment BarredThe IRS could not assess tax attributable to the final partnership administrative adjustment (FPAA) because the Code Sec. 6229(a) statute of limitations expired before the IRS issued the FPAA. And because any omission from LLC’s gross income was less that 25 percent of its reported gross income, Code Sec. 6229(c)(2) did not extend the Code Sec. 6229(a) period of limitations.DTDV, LLC, TC Memo. 2018-32, Dec. 61,140(M)last_img read more

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