Although gifts of family holding company
stock would be subject to the impact of Chapter 14, the techniques used to reduce or avoid the effect of these valuation rules will also work with a family holding company
(see pages 424-425, and Q 911-912, Tax Facts on Insurance & Employee Benefits (2010)).
No rational explanation exists for providing the benefits of the AJCA to a stand-alone bank while denying them to a bank operating as a subsidiary of a holding company
, or operating as a QSub.
In a mutual-holding-company conversion, the original mutual insurer becomes a stock insurance company that is wholly owned by a mutual holding company
In order for an issuing bank holding company
to include the stock in tier 1 capital, it must have the ability to defer payments for at least 20 consecutive quarters without giving rise to an event of default.
Since 1956, when the first Bank Holding Company
Act was passed, the Fed has regulated bank holding companies.
Herky Hawk Financial Corporation ("Herky Hawk"), a bank holding company
within the meaning of the Bank Holding Company
Act ("BHC Act"), has requested the Board's approval under section 3 of the BHC Act (12 U.
A holding company
is a corporation that holds shares in other corporations for investment purposes.
and will become a wholly owned subsidiary of a new publicly traded holding company
, The Phoenix Cos.
The conduct of activities abroad by a bank holding company
, member bank, or Edge and agreement corporation, whether conducted directly or indirectly, must be confined to the activities of a banking or financial nature and to those activities that are necessary to carry on such activities.
By avoiding the consolidated E&P rules, the holding company
will have no accumulated E&P and will calculate its E&P on a standalone basis going forward.
Section 106 of the Gramm-Leach-Bliley Act of 1999 expanded the coverage of section 109 of the Interstate Act to include any branch of a bank controlled by an out-of-State bank holding company
Historically, the Netherlands has been an attractive place to locate a holding company
, due to the combination of its extensive treaty network and its internal tax laws that minimize the amount of potential double taxation on earnings repatriated from other countries.