Also, mutual holding
companies aren't answerable to the market on a quarterly basis to the same extent as stock companies.
172--What are the holding
periods permitted for merchant banking investments?
To defeat the tax agency's argument that the structure is merely a tax gimmick without substance and that the debt owed by Target to Holding
should be disregarded, Target and Holding
must be able to demonstrate that the debt had the form of a debt instrument, that the parties intended that it be a debt instrument, and that economically the instrument was a debt.
I simply want the freedom to decide when holding
hands in church is right for me when it will be a grace and not an aggravation.
The real benefit of the expansion of the AJCA provisions to depository holding
companies is for existing C corporations, with IRA shareholders, that are considering electing S status.
A) Hosting an electronic marketplace on the financial holding
company's Internet web site by providing hypertext or similar links to the web sites of third party buyers or sellers.
31) The parties stipulated that the taxpayer occasionally sold assets of the type in question, but the court pointed out that its purpose in holding
the assets was to produce petroleum and not to sell the property.
In today's hot real estate market, many taxpayers are recognizing significant gains when disposing of their real estate holdings
And most important, the rule seeks responsibly to come to grips with the very real safety and soundness risks to an insured depository institution affiliate of both a financial holding
company that engages in merchant banking and a bank holding
company that invests in equities using existing authorities.
Under paragraphs (e), (f), (g) and (h) of this section, transactions in certain property give rise to gain or loss included in the computation of foreign personal holding
company income if the controlled foreign corporation holds that property for a particular use or purpose.
10 means the transference of the subsidy to a wider range of financial businesses, producing distortions in the competitive balance between those latter units that receive a subsidy and identical units that do not--whether those units are subs of holding
companies or totally independent of banking.
The tax law is not clear as to whether the acquisition of the assets of a holding
company by its less-than-80%-owned subsidiary satisfies the continuity-of-business-enterprise (COBE) requirement, a necessary element to qualify the acquisition as a tax-free reorganization.