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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 former subsidiary (now owned by the parent company's shareholders, but separate from the parent company) then merges with a target company to create a merged company. 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 ...
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).
A fall from grace. Founded in 1978, The Container Store went public on Nov. 1, 2013, pricing its initial public offering at $525 per share. By the close of trading that day, shares closed at $543.
Price: $1. The pinkish cheese powder didn't look promising, but once it cooked down, the sauce did indeed become thick and creamy. It tasted mellow and buttery, with slight cheesy flavor. Very slight.
WaveTrue, Inc. ( f/k/a Profile Technologies, Inc.) Announces Reorganization and Exit from Chapter 11 Business Wirevia The Motley Fool Updated July 14, 2016 at 9:56 PM
As part of the reorganization into pentomic divisions, the 8th Field Artillery Battalion was relieved from the 25th Infantry Division, reorganized and redesignated as the 8th Artillery, and assigned to the Department of the Army as a parent regiment under the Combat Arms Regimental System and, after 1981, under the U.S. Army Regimental System.
Add former Gov. Chris Christie to the list of New Jersey residents reporting mysterious "drone" sightings outside of their homes. As reports of strange lights seen in the sky in New Jersey and ...