1.368-2(b)(1)(iii), Example (9), a stock acquisition of a target followed by the conversion of the target from a corporation to an LLC under state law cannot qualify as a statutory merger or consolidation.
Accordingly, Y's acquisition of V's assets does not qualify as a statutory merger or consolidation for Sec.
It indicated that a stock acquisition followed by state law dissolution (as opposed to conversion) would not qualify as a statutory merger for the same reasons.
He inquired whether such expenditures qualify as a proper reinvestment of the repatriated funds.
Twinem referred to section 3.04(7)(d) of Notice 2005-14, which provides that software delivered to customers by downloading the software from the Internet qualifies for the section 199 deduction whereas gross receipts from software offered for use online does not qualify as domestic production gross receipts.
If the sale or other transaction were made by a party that did not manufacture the property, she said, nearly all resales of property would qualify as domestic production gross receipts.
Supervision by managers other than first-line managers does not qualify as direct supervision, even if those managers are qualified research scientists themselves.(91)
Interviews with technical personnel who have been fully educated about the tax requirements regarding activities that qualify as research or experimentation should be performed as soon as the need for the information is discovered, and should routinely be performed when any such personnel leave the taxpayer's employment.
Although some of these amounts might also qualify as a deductible/tax-free WCFB, the qualified EAP rules apply first.
Jessica's travel expenses to attend the Florida seminar do not qualify as educational assistance under Sec.
If the transfers were to different purchasers and used separate exchange agreements, they would probably qualify as
The Supreme Court also ruled that voluntary contributions of unencumbered property to a qualified plan by a disqualified party will not qualify as
Some (but not all) types of trusts may qualify as S shareholders; as such, several commonly used estate planning techniques involving trusts must be modified before they can be used in conjunction with S stock.
Certain nonforeign trusts can qualify as S shareholders.
678 trusts generally qualify as S shareholders provided the entire trust is treated as a grantor trust.