338-4(h)(2) provides for application of the consistency (carryover basis) rules to assets sold by a controlled foreign corporation (CFC) of a domestic target
corporation to a purchaser where the gain on the sale gives rise to Subpart F income under section 951(a)(1)(A) -- effectively increasing the stock basis of the target
I suppose you could argue that any place is a potential terrorist target
,'' said John Miller, terrorism czar for the Los Angeles Police Department.
The Service also noted that the acquiring subsidiary's preferred stock in the target
had such little value that value shifts in the target
were unlikely to affect the value of the acquiring subsidiary's assets (and, thus, the parent's value).
Until recently, the Internal Revenue Service (IRS) had assented to the deductibility of expenses incurred by a target
in resisting a tender offer.
On that date, the portion of the total consideration paid to the target
by the acquirer is measured to determine whether the COI requirements are met.
It is imperative for the front shoulder to point directly at the target
At LANSCE, a 120 [micro]A, 800 MeV proton beam pulsed at 20 Hz impinges on a tungsten spallation target
; MeV neutrons emerging from the target
are cooled in a liquid hydrogen moderator and transported via a supermirror guide to the experimental apparatus (Fig.
Executives at Neiman Marcus and Nordstrom, both tenants in the center, encouraged the deal with Target
, Green said.
The iSCSI storage target
can be located on the same network within the building or halfway around the world.
A discussion of several specific issues that public company management should examine in conducting a Sarbanes-Oxley "audit" of an M & A target
central bank to adopt an inflation target
or inflation target
The use of mirror debt will create an actual liability on the part of Target
rather than merely be an accounting entry.
You can also control marketing expenses because you will not be marketing to outdated target
markets or offering programs that people do not want.
Once deputies determine that a vehicle contains a suspected felon or an impaired driver, they do not take any overt action that might alert the occupants of the target
vehicle of impending law enforcement action.