112) Similarly, such regulations may provide for a reduction in the basis of the stock of the distributing
corporation to reflect the change in the value and basis of the distributing
355(d) to require Distributing
to recognize gain on a "disqualified" distribution (one in which any person owns 50% or more of Distributing
or Controlled) if the interest was acquired in a taxable transaction within five years of the distribution.
96-30 include (1) the detailed information, representations, and documentation required for establishing a valid corporate business purpose; (2) a description of the facts and circumstances that may qualify the business purpose; (3) a description of each purpose for the spinoff, not just the corporate business purpose; (4) the required information and representations from foreign shareholders and foreign corporations; and (5) the required information and representations where Distributing
joins in filing a consolidated return.
If a complicated set of requirements is met, including (a) no more than five individuals or corporations directly own 100% of the distributing
corporation's stock immediately before the distribution, (b) the distributee directly owns the corporation distributed for five years after the distribution and (c) the foreign distributee is a resident of a U.
Adding Target Distributing
to our list of authorized distributors is designed to accelerate that growth by leveraging Target's expertise as a true convergence distributor, as well as access to new reseller partners.
However, in what came to be known as a "Morris Trust transaction," the Service did not require gain recognition if either Distributing
or Controlled were subsequently acquired in a tax-free transaction.
Alternatively, the AAA bypass election allows a shareholder to receive his PTI account; by distributing
PTI, the corporation preserves its AAA.
This agreement provides Computer Telephony Distributing
with the ability to distribute CallRex to Zultys resellers throughout the United States and Canada," said Robert Kapela, product manager of Telrex.
property that has not appreciated solves the problem of corporate level gain on distribution, but it creates another problem - deferral of the $5,000 loss that the corporation would recognize if it sold the equipment outright.
Clearly Canadian Beverage Corporation (OTCBB:CCBC) (TSX:CLV) today announced that it has entered into new distribution arrangements with Columbia Distributing
Company ("Columbia") and expanded distribution arrangements with Walton Beverage Company ("Walton").
Can an S corporation generate investment income for purposes of the investment interest limitation by distributing
The Computing Technology Industry Association (CompTIA) and D&H Distributing
, one of America's oldest and largest wholesale products distributors, announced today they are working together to promote the certification of technicians in the home integration market.
312-10(a) provides that, for a newly created controlled corporation, the allocation of E&P generally should be made in proportion to the fair market value (FMV) of the business (and interests in any other property) retained by the distributing
corporation and the business (and interests in any other property) held by the controlled corporation immediately after the transaction.
Synchronization Server is capable of distributing
signage in real time at the store level