In contrast, the acquisition of a foreign corporation that, in turn, owns a domestic corporation, is not an indirect acquisition of such domestic corporation for Sec.
Example 1: Foreign corporation Y acquires foreign corporation X.
Yet as the vehicle for these pecuniary urgings, the corporation posed a big dilemma.
The centralized economic power of the corporation requires institutional counterweights in the form of a strong federal government, as well as labor unions and organized citizen groups.
In summary, the Court unequivocally held that Alabama's foreign corporation franchise tax was unconstitutional, as a violation of the Commerce Clause, and therefore could not be enforced.
The mere issuance of this opinion requires every multistate corporation to carefully compare its individual tax burden in states where it is a foreign corporation to the burden borne by its native counterparts.
For example, assume that a shareholder organizes a corporation and contributes as its only asset a building with a basis of $50 and a fair market value of $100; the property is subject to a mortgage debt of $90.
On the facts of the example, recognition of $40 of gain will leave the taxpayer with a basis in his stock in the corporation of $0, thereby eliminating the negative basis.
Technically, a QSub is neither a C nor an S corporation
and generally is not treated as a separate corporation
for Federal tax purposes (although it is still treated as a separate corporation
for other purposes).
To get automatic relief, the corporation
must file a completed S election, signed by an authorized corporate officer and by all persons who were shareholders at any time during the period the entity had intended to be an S corporation
The acquisition of stock in the controlled corporation
by the distributing corporation
Bering Straits is the regional corporation
for Alaska's wind-swept Seward Peninsula and for St.
This two-part article discusses recent legislation, cases, rulings, regulations and other developments in the S corporation