Until the government issues guidance that addresses some of the issues raised by TAM 200604033, taxpayers will be left wondering whether their existingVPFs and stock loans "work" and whether stock loans should be avoided altogether when entering into
Both the existing and the proposed long-term contract regulations contain aggregation provisions comparable to those for severance--that is, they provide that several separate contracts generally will not be aggregated unless (1) the separate contracts would be treated as one contract under customary commercial practice in the contractor's trade or business or (2) there is no business purpose for entering into
several agreements rather than one.
The taxpayer had also undermined its business purpose by entering into
a "mirror" swap to eliminate its risk under the original swap.
The entering into
of the new credit facilities and the completion of the G International acquisition and related refinancing are subject to a number of conditions, including market conditions.
1259 is designed to prevent a taxpayer from entering into
long-term hedging transactions that would defer gain indefinitely while substantially reducing or eliminating the risk of loss.
Recognition of gain on certain appreciated positions in personal property: This proposal would require a taxpayer to recognize gain (but not loss) on entering into
a constructive sale of any appreciated position in stock, a debt instrument or a partnership interest.
Simultaneously with the entering into
of the Share Exchange Agreement, and pursuant to its terms, Eduard Will, President and CEO of Inprimis, C-4 and another investor entered into a Private Placement Agreement under which Inprimis will, subject to certain conditions, issue 4,000,000 shares of a newly created class of Series A Preferred Stock in consideration of an aggregate purchase price of $500,000.
Many employers offer financial assistance to key employees that enables them to purchase life insurance, by entering into
arrangements in which the employers advance the amount necessary to pay all or part of the annual premium in exchange for the employee's obligation to repay the advances out of the policy proceeds.
At the time of entering into
the Underlying Agreement Cominecsa was at arms-length to the Company.
WIC has indicated in its Directors' Circular that it either already has or is in the process of entering into
long-term contracts or special termination agreements with certain key senior executives" said Leonard Asper, CanWest's Director of Corporate Development.