In this post, Cummings clarifies how corporate and business taxpayers can avoid having to conjure up a business purpose for an acquisitive reorganization, other than the acquisition. 1. Point of article. A good place to start the examination of the business purpose issue is Rev. Proc. 86-42, 1986-2 C.B. 722, the previous guidelines for letter rulings on acquisitive reorganizations. That which was the IRS thinking when it didn’t require a business purpose representation? A B, C, D, or G reorganizations (that do not involve divisions) to fulfill the COBE requirement. The quoted vocabulary originates from the COBE legislation, reg. It suggests treating business purpose as a necessity separate and unique from COI and COBE. But it does not prevent dealing with COBE as a continuing business purpose for acquisitive reorganizations. Is this a great country or what?

The owner by the way was fantastic, constantly travelling to check on everyone and make sure they were having an enjoyable dinner. This is by the best food we’d while in the Seychelles significantly, and I’d recommend eating here when visiting Praslin. With its modern villas, new facilities and amazing location and views the Raffles is widely regarded as one of, if not the best, hotels on Praslin, and has everything would have to be a world-class holiday resort.

I really wanted to love this place, but I didn’t. It was an extremely clear rung below the Four Seasons, and it all comes down to the tiny things that oftentimes the Raffles simply didn’t get right. Service: it isn’t like they lack in bodies, there’s actually a great staff-to-guest ratio.

I think the problem is that the staff lack proper path, with a chance for a full operational makeover here. For instance, our calls to the lobby were only answered 50% of that time period, yet each time we walked by the lobby there were no fewer than 5-10 people standing around. Amenities: no slippers or beach bag were provided to guests. Given that this is a beach resort, I’ve no hint why they don’t really provide a beach handbag for use during the stay.

Everywhere we went we noticed guests getting their Constance Lemuria luggage around, and will be a perfect opportunity to build the Raffles brand and advertise with their guests do the same. Villa: I completely understand that at island hotels things can fail, but neither of the issues we came across were handled satisfactorily.

First, our hot water heating unit fuse blew out and required 3 visits from the repairman before it was correctly fixed. Second, our phone line died multiple times which required us to walk down to the lobby to speak with someone. No dry area: This one really remaining me baffled, our villa had no outdoor space available to hang dry our clothes literally, which is essential at a beach holiday resort.

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There was a series mounted on the outdoor shower, but with no cover and continuous rain imaginable how effective that was. And the outdoor patio got a small area that was protected, but the breeze blew the rain directly into that area and would again keep things damp. I’d still recommend the Raffles to others who are looking for a resort on Praslin, but I certainly think there’s room for improvement here. Hopefully these little things can be tackled, because in theory they should be the easiest to fix also.

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