If the distributing
corporation retains some stock in the controlled corporation, it must at least distribute control of the controlled corporation, and it must show why the retention of the stock was not in pursuance of a plan having as one of its principal purposes the avoidance of Federal income tax.
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.
extends 3Com's reach into the VoIP market through its extensive and deep relationships with value-added resellers.
If there' was a reorganization involving either Distributing
or Controlled within two years of a Sec.
This technology is a ground-breaking step to increase the productivity of engineers through distributed computing," said Silvina Grad-Freilich, distributing
computing product manager, The MathWorks.
all AE&P (or at least the C portion) before the end of the year in which the PII ceiling would be exceeded, the corporation can avoid both the PII tax and possible termination of the S election.
E[acute accent]"We are looking at schematics of shelf layouts with store managers to make sure our products are positioned properly and checking inventory availability in real time for large orders," said Premium Distributing
Operations Manager John Stange.
If the shareholders do not want to report gain from the distribution, they could consider distributing
to Bob equipment with a higher basis in relation to its FMV so that gain at the corporate level could be reduced or eliminated.
Telrex, the leading developer of packet-based, VoIP call recording and monitoring software for small and medium businesses with IP or IP enabled PBXs and Computer Telephony Distributing
, a distributor for the Zultys IP PBX in the US and Canada, today announced the signing of a distribution agreement.
Can an S corporation generate investment income for purposes of the investment interest limitation by distributing
Distributed Online Delivery of Content -- Improve bandwidth utilization, minimize costs, and increase speed of end-user access by distributing
content across multiple networks, datacenters, and geographic locations.
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.
What's more, by distributing
SharePoint documents to the edge of the network in a fashion transparent to the user, the Certeon Distributed Collaboration Platform accelerates the performance of the network while preserving its ease of use and keeping document versions synchronized across locations and domains.