According to the IRS, the agreements entered into
by the parties required the taxpayer to consent to each stock loan.
Notice 2002-8 contains guidance for arrangements entered into
before these regulations are effective.
Concurrently with the issuance of the regulations, the IRS issued a notice of proposed rulemaking (FI-34-94),(2) relating to the character and time for recognition of certain hedging transactions entered into
by members of an affiliated group filing consolidated returns.
55) The proposed regulations would also provide that if an agreement is modified to increase the number of items to be supplied under the agreement--for example, by the exercise of an option or the issuance of a "change order" --the additional items generally should be treated as a separate contract or as several separate contracts and should be treated as entered into
on the date the contract modification becomes effective.
501(c)(3), even though it had entered into
a joint venture with a for-profit partner; St.
The Company entered into
a non-exclusive license with Kirin.
X later entered into
a second agreement, under which the first agreement was amended and restated in its entirety.
In November 2005, the Company entered into
a participation agreement with Addax with respect to Block 4 of the JDZ where Addax paid the Company $1.
They will also automatically be entered into
the grand prize drawing.
Also in February of Year 3, A and T entered into
an agreement entitled "Agreement of sale of goodwill and covenant not to compete" (Agreement).
SANYO) (Nasdaq:SANYY) today announced that it had entered into
a basic agreement with Daiwa SMBC Principal Investments ("Daiwa SMBCPI"), the Goldman Sachs Group and the Sumitomo Mitsui Banking Corporation relating to SANYO's plan to increase its share capital.
In an attempt to repatriate foreign earnings without incurring tax, a taxpayer entered into
a swap and then sold income rights under the swap to its foreign subsidiaries.
In connection with the offering, OSI has entered into
call spread transactions with respect to its common stock with an affiliate of the initial purchaser of the notes.
197-2 provides that a covenant not to compete entered into
between a corporation and a shareholder on a corporation's redemption of a shareholder's stock is a Sec.
Maverick entered into
a portion of these repurchases contemporaneously with the pricing of the notes.