Each assumes a vertical breakup, but watch out for securitization.
It can prove difficult to detect any overt difference of opinion among financial credit rating agencies. That...
determine the transferee's ruling amount, with respect to the interest acquired, by prorating the transferor's schedule of ruling amounts over the taxable year, while making any required percentage adjustment if the transferor did not transfer its entire qualifying interest. See Treas. Reg. 1.468A-6(e)(2)(i)(B)(ii)(3) for an example of this section.
13 A liability determined for regulatory purposes will qualify as "fixed and quantifiable." See, Joint Committee Report, supra note 4.
14 Treas. Reg. sec. 1.461-4(d)(5).
15 Joint Committee Report, supra note 4.
16 Joint Committee Report, supra note 4.
17 Joint Committee Report, supra note 4.
18 Stranded Nuclear Waste - Implications of Electric Industry Deregulation for Nuclear Plant Retirements and Funding Decommissioning and Spent Fuel, Bruce Biewald and David White, Synapse Energy Economics, Inc., Jan. 15, 1999.
19 PECO Energy Testimony, supra, note 1.
20 Public Power Testimony, supra, note 3.
21 Energy Notes, Current Legal Issues in Energy and Public Utility Law; Thelen, Reid & Priest, Summer 1999.
22 PECO Energy Testimony, supra, note 1.
23 Treas. Reg. sec. 1.468A-2.