125) In the case of a section 355 distribution, section 358(b) provides that, under regulations prescribed by Treasury, the basis shall be allocated between the stock of the controlled corporation received and the stock of the distributing
368(a)(2)(H)(ii) and instead provided that, in determining whether a transaction qualified as a divisive D reorganization, the fact that the shareholders of Distributing
dispose of all or part of the Controlled stock is not taken into account.
The funds can be raised with less cost or effort if Distributing
and Controlled are separated through a distribution.
Given our long history with both Target Distributing
and 3Com, we're extremely excited to now have combined access to Target's outstanding service and support and the product portfolio from one of the true leaders and innovators in IP telephony," says Bob Rankin, general manager, Telephony and Data Solutions of Dublin, OH.
If either Distributing
or Controlled is acquired in a plan that existed at the time of a Sec.
312(h) provides some guidance on the allocation of AE&P between two or more corporations resulting from a divisive reorganization, it is silent on the allocation of AAA among the corporations when the distributing
corporation is an S corporation.
Privately owned, Columbia Distributing
Company is the Pacific Northwest's largest beverage distributor.
all of the AE&P eliminates the risk that the corporation will be subject to tax on passive income and the risk that the S election will be terminated because excess net passive income was received for three consecutive tax years.
As the leading distributor in the Digital Convergence market, we are seeing a significant pattern of increased cross-category purchasing behavior among our computer resellers," said Dan Schwab, vice president of marketing at D&H Distributing
355/D reorganization transaction based on the relative FMVs of the distributing
and controlled corporations is a standard representation that the Service requires in private ruling requests.
PeerDirect now provides the components required for a fully mobilized application architecture: mechanisms for distributing
applications and data, and a management console for keeping all instances of applications and data in sync," said Steve Garone, chief analyst and managing partner of The AlignIT Group.
Another new initiative that addresses business continuity, PeerDirect, an operating company of Progress Software Corporation, provides its customers with an added layer of business continuity insurance by automatically replicating, distributing
and synchronizing their corporate data across multiple locations.
The PeerDirect Distributed Enterprise suite lets companies decentralize their business applications by automatically and bi-directionally synchronizing, distributing
and replicating corporate data and applications across multiple locations, desktops and mobile devices, while providing centralized tools for easy administration.
ADAMS is an application that enables a seamless, enterprise-wide solution for transferring, distributing
and managing large files via Lotus Notes-email.
PeerDirect Distributed Enterprise accomplishes this by synchronizing, distributing
and replicating corporate data and applications across multiple locations, while providing IT departments with a centralized console for easy administration.