355 tax-free spin-off. The new rules also address whether a corporation is engaged in a trade or business through attribution of trade or business assets and activities from a partnership.EBSCO_bspFederal Tax Course Letter
A tax-free spinoff refers to a corporate action in which a publicly traded company spins off one of its business units as an entirely new company without tax implications. This type of transaction is deemed to be "tax-free" because the parent company is still able to divest the business i...
If enacted in its present form, the Build Back Better Act (BBBA) would amend the U.S. tax code’s rules for tax-free spin-off and split-off transactions (spin-offs), imposing significant restrictions on a parent company’s ability to reallocate debt to the spin-off company withou...
摘要: Focuses on the ruling won by Williams Cos. from the United States Internal Revenue Service allowing for a tax-free spinoff of Williams Communications Group Inc. Details on the rulings; Shares of the company's stocks.年份: 2000
Tax-free spin-off of the United States Public Sector business of DXC Technology Tax-free spin-off of the Powertrain Systems Segment of Delphi Automotive to its shareholders Tax-free spin-off by Archrock, Inc. of Exterran Corporation to its shareholders Acquisition by LogMeIn of the GoTo business...
Impose new restrictions on tax-free spin-offs:The Green Book proposes significant changes to the U.S. tax code’s rules governing tax-free spin-off and split-off transactions (Spin-Offs). A Spin-Off generally involves the separation of a historic business line of a parent company (Pa...
In its operational, regulatory and strategic complexity, a tax-free spin-off is something of a three-part challenge: as demanding as any business carve-out, with added requirements akin to those of an IPO, plus the close involvement of tax authorities and the SEC. In assessing the most crit...
Given that an RMT transaction is composed of two steps (a tax-free spin-off under section 355 and a tax-free reorganization under section 368), there are distinct tax rules to be satisfied. In addition, the implementing agreements often contain restrictions on post-closing activities that could...
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that would displease Mr. Erdogan. A total of 23 individuals were affected by the asset seizure. If these individuals had been able to shield their assets from the Turkish government, they would have been free to oppose the Erdogan regime while working, investing, and developing their businesses...