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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.
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.
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 ...
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2022 revision of Form 990. Form 990 (officially, the "Return of Organization Exempt From Income Tax" [1]) is a United States Internal Revenue Service (IRS) form that provides the public with information about a nonprofit organization. [2] It is also used by government agencies to prevent organizations from abusing their tax-exempt status. [3]
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.
Now, at 33, my interest is revving up and I am ready to fill my life with more romantic love. With my mind and heart as open as ever, I decided to try a method I was curious about: modern ...