150213(c)(6)(i) exemption, when an exempt investment is directly traceable to debt recurred by a related affiliate
to an unrelated lender.
9), which parallel the surplus suspension rules described above, and will generally apply to the sale of the assets of a business to other affiliates
or non-arm's-length persons, other than such sales occurring in the ordinary course of business.
KRON sold for $823 million primarily because it was the NBC affiliate
Repeal of the interlocks and cross-marketing restrictions allows increased synergies in the operation of a section 20 subsidiary and its bank affiliates
As part of its role to enhance the ability of the state and/or local community to serve the individual who is deaf-blind in his/her own community, the affiliate
shares information and combines expertise to provide or improve services for persons who are deaf-blind.
In addition, AMG provides centralized assistance to its Affiliates
in strategic matters, marketing, distribution, product development and operations.
1) will be clarified by deleting the words suggesting that the two affiliates
must be resident in the same country; although the CCRA had not interpreted the paragraph as imposing that requirement, the words are ambiguous; and
Circuit City's affiliate
marketing program, now managed by Performics, enables leading Web publishers to offer a wide range of consumer electronic brands and products to their loyal online shoppers.
Indeed, corporate groups often choose to hold intangibles in separate affiliates
in order to facilitate the exploitation and management of those intangibles, to shield the intangibles from liabilities associated with manufacturing and other activities, and to otherwise enhance and protect their intellectual property interests.
Additionally, the Komen Central Wisconsin Affiliate
has already distributed a request for proposals to award their first grants in the area.
Under the proposed legislation, two different levels of foreign affiliate
information returns are contemplated: a detailed return for "controlled" foreign affiliates
and a simplified return for "non-controlled" foreign affiliates
PrimaryAds presents affiliates
with exclusive, well-converting offers that pay the industry's highest commission rates.
4 requires taxpayers with foreign affiliates
to provide additional financial and tax information with respect to each affiliate
Digital River's affiliate
development team works directly with affiliates
to tailor a combination of programs and technologies designed to help them expand their online businesses.
On November 21, 1994, Tax Executives Institute filed the following comments with the Canadian Department of Finance in respect of the draft legislation concerning foreign affiliates