Repeal of the interlocks and cross-marketing restrictions allows increased synergies in the operation of a section 20 subsidiary
and its bank affiliates.
parent corporation arranged for its wholly owned Netherlands Antilles subsidiary
to borrow from various foreign lenders.
Steel had issued parent company statements that included as income only the devidends received from subsidiary
NewMarket maximizes shareholder return on investment by independent listing of consolidated regional and emerging technology subsidiaries in order to issue subsidiary
stock in shareholder dividends.
1502-32(g), the common parent of an affiliated group would have to attach a statement to the group's consolidated return each year reflecting the net investment adjustment with respect to each subsidiary
joining in the consolidated return.
NewMarket has also announced plans to create a publicly listed intellectual property subsidiary
in which the company will consolidate existing and yet-to-be acquired intellectual property still under development.
Nondeconsolidating dispositions: If stock of a subsidiary
member (with a basis exceeding its value) is exchanged, and the subsidiary
member remains a group member, the BRR applies.
Supreme Court, on the other hand, requires that the activities of the subsidiary
that generates the income be part of the parent's unitary business conducted in the state and has not differentiated between dividends, interest and capital gains.
Observation: In this letter ruling, the IRS pierced the "equity wall" of a foreign finance subsidiary
used for inbound financing.
A third subsidiary
is also in the process of being publicly listed.
368(a)(1)(A) if, as part of an integrated plan, (1) an acquiring corporation acquires all of the target's stock through a reverse subsidiary
merger in which the target shareholders receive consideration consisting of 70% stock and 30% cash (this transaction, considered by itself, would be a taxable transaction); and (2) the target then merges into the acquirer.
Some who would require sale-leaseback accounting in the consolidated financial statements also believe parallel treatment should be followed in the separate subsidiary
section] was issued on March 9, 1990, disallowing a loss recognized on the disposition of stock of a consolidated subsidiary
on or after that date.
The problem with centralized reporting, however, is that it is an arduous task for both the subsidiary
and the central treasury, so the frequency of reporting is low, usually once a month.
Under that rule, a loss on a subsidiary
stock sale is not disallowed to the extent that a taxpayer establishes that the loss is not attributable to the recognition of built-in gain (BIG) on an asset disposition.