Coding With Fun
Home Docker Django Node.js Articles Python pip guide FAQ Policy

Which is an exception to the initial contract exception?


Asked by Callahan Nicholson on Dec 03, 2021 FAQ



Initial Contract Exception - Intermediate Sanctions (IRC 4958) Section 4958 does not apply to any fixed payments made by an organization to a disqualified person pursuant to an initial contract.
Likewise,
Treatment as a new contract may cause the contract to fall outside the initial contract exception, and it thus would be tested under the fair market value standards of section 4958.
Next, There are two very important exceptions to the contractual liability exclusion. The first, is that the contractual liability exclusion does not apply to liability for damages that “the insured would have in the absence of the contract or agreement.” Think tort claims.
Similarly,
Exception handling based on design by contract. A different view of exceptions is based on the principles of design by contract and is supported in particular by the Eiffel language. The idea is to provide a more rigorous basis for exception handling by defining precisely what is "normal" and "abnormal" behavior.
In this manner,
An initial contract is a binding written contract between an applicable tax-exempt organization and a person who was not a disqualified person immediately before entering into the contract.