References in periodicals archive ?
In a mutual-holding-company conversion, the original mutual insurer becomes a stock insurance company that is wholly owned by a mutual holding company.
10) Subpart J governs the conduct of merchant banking investment activities by financial holding companies as permitted under section 4(k)(4)(H) of the Bank Holding Company Act (12 U.
Under this strategy, if Target pays interest expenses to Holding that matches or almost matches the interest expense paid by Holding to third parties, the operating income of Target should be effectively sheltered.
I must confess, there was a bit of romance involved in that situation, but having a woman already holding a crumpled tissue decide we should hold it together to pray is something else.
Language was inserted in the early versions of the correcting legislation expanding the IRA-related provisions to depository holding companies by amending Secs.
And most important, the rule seeks responsibly to come to grips with the very real safety and soundness risks to an insured depository institution affiliate of both a financial holding company that engages in merchant banking and a bank holding company that invests in equities using existing authorities.
Huddleston, the Supreme Court of Tennessee, in holding that gains from the sale of shopping centers were nonbusiness income, said that the taxpayer was not in the business of selling real estate, noting that its principal business activity was to own and lease shopping centers to retailers, including its corporate parent.
Dealer status will not automatically disqualify a taxpayer from holding certain property for investment; however, it would seem that dealers may have to sustain a heavier burden to prove that fact.
However, it added a caveat to the requested ruling: "[N]o inference should be drawn from this letter that any gain from the sale of [H&C's] assets immediately following its election to be disregarded as an entity separate from its owner gives rise to gain that is not foreign personal holding company income as defined in section 954(c) (1)(B).
This bill would permit smaller bank holding companies to provide limited equity capital to customers of the subsidiary banks.
5 -- The Greater New York Chapter of the Institute of Real Estate Management is holding an educational course titled, "Solving Real Estate Math Using the HP-19BII Calculator" from 1 to 5 p.
The tax law is not clear as to whether the acquisition of the assets of a holding company by its less-than-80%-owned subsidiary satisfies the continuity-of-business-enterprise (COBE) requirement, a necessary element to qualify the acquisition as a tax-free reorganization.
While the proportion of families holding checking and savings accounts declined over the period, the families that held these accounts in 1989 maintained them at about the same real level as that in 1983, with the median value of checking accounts rising only from $600 to $900 (tables 4 and 5).