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Under Internal Revenue Code section 368(a)(1)(A), this transaction could be largely tax-free if the former subsidiary is considered the "buyer" of the target company. The former subsidiary is the "buyer" if its shareholders (also the original parent company's shareholders) own more than 50% of the merged company.
The "Killer B" strategy is a tax-avoidance strategy that reduces a firm's taxes owed on the repatriation of foreign cash used in the acquisition of another firm through the classification of an acquisition as a reorganization provided by Section 368(a)(1)(B) of the Internal Revenue Code.
This requirement is correlated with the non-device requirement by stating the stronger the business purpose of the corporation is, the less evidence of device in the purpose of the transaction. Revenue Procedure 96-30 provides some examples of advance rulings on business purpose.
WaveTrue, Inc. ( f/k/a Profile Technologies, Inc.) Announces Reorganization and Exit from Chapter 11 NEW YORK--(BUSINESS WIRE)-- WaveTrue, Inc. (OTC Pink: PRTK.Q) formerly known as Profile ...
Simply an operation having no business or corporate purpose-a mere device which put on the form of a corporate reorganization as a disguise for concealing its real character, and the sole object and accomplishment of which was the consummation of a preconceived plan, not to reorganize a business or any part of a business, but to transfer a ...
Most countries exempt certain types of corporate events or transactions from income tax. For example, events related to the formation or reorganization of the corporation, which are treated as capital costs. In addition, most systems provide specific rules for taxation of the entity and/or its members upon winding up or dissolution of the entity.
Price on eBay: $8,500 Porcelain dolls don’t have to be more than 2 feet tall to be worth a lot of money. This little lady stands only 15 1/2 inches tall, but her ornate details and impressive ...
Directed by Martin Scorsese, the movie stars Leonardo DiCaprio as Belfort, who engages in every form of depravity known to man as he gets rich from his criminal behavior.