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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]
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The Commissioner of Internal Revenue, Guy T. Helvering, argued in economic substance there was no business reorganization, that Gregory owned all three corporations and was simply following a legal form to make it appear like a reorganization so she could dispose of the Monitor shares without paying substantial income tax. Accordingly, she ...
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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.
After Arizona State's Big 12 championship win, Kenny Dillingham said the Sun Devils "should be treated like an 11-1 team" in Sunday's CFP rankings.