Lynn said expanding Project Fair Play to also report churches that distribute
biased voter guides -- whether they promote Republicans, Democrats or candidates from other parties -- seemed a logical step.
96-30),(69) but the distribution does not prevent such a takeover, the distributing corporation arguably can distribute the controlled corporation with no plan that another party would acquire 50 percent or more of the stock of the distributing or controlled corporation.
128) Under the section 355(a)(1)(D) control test, the distributing corporation is required to be in control (again, 80 percent of the voting power and 80 percent of each other class of stock) of the controlled corporation immediately before the distribution, and the distributing corporation must distribute to its shareholders all of its stock in the controlled corporation.
The PTI bypass election: In some situations, a corporation with both PTI and AE&P may want to distribute AE&P first.
If X elected to bypass AAA and PTI, it could distribute $5,000 and eliminate its AE&P.
In this situation, Jacorp can distribute
$5,000 in cash and tract #3 (with a net equity of $55,000) in redemption of John's stock without recognizing gain.
As a general rule, however, assets with basis in excess of FMV should not be distributed to a shareholder because the potential loss cannot be used by either the corporation or the distribute
In addition, the trust authorized the trustee to distribute
all or a portion of the corpus to one of the two named beneficiaries.
The three choices produce the same net taxable result for Dick in the current year, except that by making the election to distribute
AE&P, the investment interest expense has been used, and the AE&P balance has been reduced by $30,000.
Rather than transmitting update files individually to each distributed server in turn, companies can use OmniCast to distribute
to them all in a single transfer.
This implementation distributes
the management task across multiple storage servers, eliminating any single point of failure and allowing the management function to scale as the cluster scales.
If the corporation distributes
the land to shareholder Adams, X has $50 of taxable income, its earnings and profits are increased by $50 and Adams has received a $200 distribution which--if there are no other current or accumulated earnings and profits--represents a $50 dividend and a $150 return of basis and capital gain.
If a corporation distributes
nonappreciated assets and keeps its appreciated assets, either Distributing or Controlled can be acquired without gain recognition.