An alternative tax strategy for exchanging into like-kind property following a cost-segregation study is to argue that reclassified personal property remains "real estate" for Sec.
2000-37 permits an EAT to borrow money from the exchanging party and for the latter to guarantee the EAT's construction loans.
This is called exchange last because the exchange of the properties, with respect to exchanging
taxpayers, occurs at the last step.
The other major exception under Notice 87-85 -- where the exchanging shareholder loses U.
If X is required to recognize gain on its outbound asset transfer (notwithstanding the "active conduct" exception of section 367(a)(3)), then only a portion of the realized gain of the exchanging shareholder of X may be subject to the indirect stock transfer rules.
As consideration for exchanging
the Old Notes for the New Notes, all holders validly exchanging
Old Notes (including those holders that have already tendered their Old Notes and do not withdraw such Old Notes prior to the expiration date) will now receive a one-time exchange fee of $7.
Endpoint Exchange helps its member institutions achieve significant return on investment in a number of ways, but most notably in two key areas: first, by leveraging a financial institution's technology investment in prime pass image capture (whether they deploy this solution In-house or through a service bureau), and second, by driving down the costs of check clearing and settlement, particularly as more and more financial institutions become members of the network and begin exchanging check images with each other.
financial institutions clear their check-based transactions by exchanging images between member banks, thrifts, credit unions, service bureaus, clearinghouses, and the Federal Reserve.
ADC's stock option exchange program is structured on a "value-for-value" principle, which will result in employees exchanging
a larger number of old options for a smaller number of new options.
Previously, Intermedia deployed the Telcordia(TM) ServiceGate gateway solution, which it has used for exchanging
Access Service Request (ASR) orders with its trading partners.
Adrian and Alina Madau know very well the frustration vacation owners have in exchanging their timeshare resort.
The owners complete their exchange by faxing (or mailing) the exchange contract received from ResorTrader to the resort they are exchanging into.
Prior to this version of Internet Exchange, Macintosh and PC cc:Mail users either experienced difficulties in exchanging
attachments across platforms or were unable to do it at all," said Joe Rohde, president of Central House Technologies.