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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.
The transaction included a $1.8 billion one-time special cash payment to Lockheed Martin. Lockheed Martin shareholders received 50.5% equity in Leidos. [5] On February 2, 2017, Entercom announced that it had agreed to acquire CBS Radio. The sale was conducted using a Reverse Morris Trust so that it was tax-free. [6]
The landmark case that has been used to determine active trade or business requirement is Estate of Lockwood v. Commissioner, 350 F.2d 712. Other relevant sources are Revenue Ruling 2003-38, which entails whether an expansion of a corporation's business constitutes a new or continuing business under Reg. 1.355-3(b)(3)(ii).
Timeline of former nameplates merging into Macy's. Many United States department store chains and local department stores, some with long and proud histories, went out of business or lost their identities between 1986 and 2006 as the result of a complex series of corporate mergers and acquisitions that involved Federated Department Stores and The May Department Stores Company with many stores ...
State Route 368 (SR 368) is a 10.6-mile-long (17.1 km) state highway in the northeastern part of the U.S. state of Georgia. It is entirely within Elbert County and connects the Elberton area with South Carolina. It was originally built in 1940 as SR 82 and was redesignated as SR 368 in 1970.
This is a list of U.S. Supreme Court cases involving Native American Tribes.Included in the list are Supreme Court cases that have a major component that deals with the relationship between tribes, between a governmental entity and tribes, tribal sovereignty, tribal rights (including property, hunting, fishing, religion, etc.) and actions involving members of tribes.
The USAF's last major reorganization of commands was in 1992. In July 2006, the Air Force Network Operations (AFNETOPS) command was stood up at Barksdale Air Force Base. At the time, it was anticipated that it would be transformed into a new MAJCOM: the Air Force Cyber Command. [2]
Reorganization Plan No. 3 was a United States presidential directive establishing the Environmental Protection Agency (EPA), effective December 2, 1970. [1] The order, published in the Federal Register on October 6, 1970, consolidated components from different federal agencies to form the EPA, "a strong, independent agency " that would ...