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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.
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 timing, venue and purpose of a State of the City Address can vary significantly depending on local history and practice. Most State of the City Addresses are held early in the calendar year, but some mayors deliver their address as late as December of each year. In many American and Canadian cities, by law or tradition, the State of 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).
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Myers v. Anderson, 238 U.S. 368 (1915), was a United States Supreme Court decision that held Maryland state officials liable for civil damages for enforcing a grandfather clause.
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 ...
Veterans Regulation No. 1 (f), Entitlement to Pensions [10] February 8, 1935 1087 6967-A February 8, 1935 1088 6968 Extension of Trust Period on Allotments Made to Indians of the Crow Creek Band of Sioux February 9, 1935 1089 6969 Code of Fair Competition for the Cigarette, Snuff, Chewing, and Smoking Tobacco Manufacturing Industry February 9, 1935