In ILM 200224007, a purported sale of partnership assets between two members of a joint venture was recharacterized as a sale of the partnership interests under the step transaction, substance over form, and sale of a going concern doctrines. Taxpayer and Company formed an international joint ...
ASSET PURCHASE AGREEMENT by and among ___ and ___ Dated ___, 20__ TABLE OF CONTENTS 1. DEFINITIONS AND USAGE 1.1 Definitions 1.2 Usage 2. SALE AND TRANSFER OF ASSETS; CLOSING 2.1 Assets to Be Sold 2.2 Excluded Assets 2.3 Consideration 2.4 Liabilities 2.5 Allocation 2.6 Closing 2.7 Closing...
The RTC did not have the capacity to resolve all the failed S&Ls and was required to contract the work out to theprivate sectorwhere practical. AMDAs were the partnership agreements that formed the legal framework for the work. Ninety-one contractors worked under these agreements in the early...
2.1. Purchase and Sale of Assets. Seller agrees to sell and transfer to Buyer, and Buyer agrees to purchase and acquire from Seller, and subject to and upon the other terms and conditions contained herein, all of Sellers right, title and interest in and to the -5- following assets of ...
(including a partnership, corporation, limited liability company or similar entity) that is a citizen or a resident of the United States or is organised or incorporated under the laws of the United States. Certain restrictions also apply to any subsequent transfer of Shares in the United States ...
9 RegisterLog in Sign up with one click: Facebook Twitter Google Share on Facebook Limitation on asset dispositions (redirected fromLimitations on Asset Disposition) Limitation on asset dispositions Abond covenantthat restricts in some way afirm'sability to sell majorassets. ...
Oaktree and AVANA Companies Form $250MM Private Credit Partnership AVANA Companies and funds managed by Oaktree Capital Management announced the formation of a new $250 million AVANA-Oaktree Private Credit Partnership ("AOPCP") for its direct private commercial real estate lending strategy. Through...
The Asset Works appoint Jones Lang LaSalle as preferred supplier of professional services The Asset Works, a global leader in leased asset management and verification services is pleased to announce a new partnership with Jones Lang LaSalle... ...
achieve sustainable economic development in China. It also analyzes theexisting challenges in the implementation of PPP asset-backed securitization(PPP-ABS) and provides policy recommendations. KEYWORDS:Asset-backed securitization; China; ESG; infrastructure financing; public private partnership; PPP-ABS...
This Article examines the impact of recent developments on a particular category of taxpayer: the S corporation whose shareholders desire to sell some or all of the corporation's assets. While an installment sale of assets has, for many taxpayers, lost much of its previous allure, such sales ...