Example 1: P, the common parent of an affiliated group that includes subsidiary S, borrows $1,000 from unrelated lender X.
The ruling holds that, similar to the proposed regulations, if an affiliated group member borrows from an unrelated party and directly loans the funds to a related dealer affiliate for the purpose of carrying on the dealer's general business, the disallowed interest expense allocation is both calculated and applied at the dealer level.
2) There is at least one case currently underway in Maryland testing whether the State may disregard a legally distinct Delaware corporation that licenses intangibles to (and receives royalty payments from) an affiliated
corporation doing business in the State.
The proposal would also continue to prohibit an affiliated bank from knowingly advising a customer to purchase securities underwritten or dealt in by a section 20 affiliate unless it notifies the customer of its affiliate's role The proposal also continues to prohibit a bank public customer information without the customer's consent.
Finally, with regard to the revenue limit, section 20 of the Glass-Steagall Act prohibits a bank from being affiliated with any company "engaged principally" in to make a narrow, legal determination of the level of revenue at which a company becomes "engaged principally.
Arthur Ochs Sulzberger, chairman and chief executive officer of The New York Times Company, said, "The combination of the Times Company and Affiliated is a once in a lifetime opportunity to form an alliance of two great companies -- one that owns The New York Times and one that owns The Boston Globe.
This alliance offers a unique opportunity for both the Times Company and Affiliated in a rapidly changing advertising environment where success depends on bold and creative new approaches.
As illustrated in the example at right, use of the attribution rules in determining affiliated groups for earnings stripping purposes can result in a profitable corporation with normal debt-to-equity ratios having its interest expense deductions limited because its foreign parent has one or more less profitable or more leveraged operations in the United States.
Indications from the Service are that the final regulations will contain some minor changes in the affiliated group rules; however, these changes would not likely affect the result in the example.
Treat the 80%-of-value requirement as having been met if the affiliated
group, in reliance on a good faith (but erroneous) determination of value, treated such requirement as having been met.
Over 150 broadcasters including broadcasters affiliated
with the nation's major networks such as ABC (NYSE:DIS), NBC (NYSE:GE), FOX (NYSE:FOX), Paramount (NYSE:VIA) and Warner Brothers (NYSE:TWX), have now registered .
com, which also operates its own independent "Affiliate Network" program from its site, is quickly building a larger base of affiliated
web sites through Commission Junction.
The "Giggles for Charity Challenge" is an in-store promotion held at participating Affiliated
Foods Southwest stores from May 2 through May 29, 1999.
Be Free offers us the advanced technology and reporting systems to manage thousands of virtual storefronts within affiliated
Be Free offers the technology and reporting systems to manage thousands of virtual storefronts within affiliated