In El Paso, of three different proposals for corporate reorganization
, the taxpayer was able to adopt the last one; therefore, the other two were not deemed to be abandoned.
In order to unlock shareholder value, the Reports recommend that the Company carry out a corporate reorganization
to crystallize and separate each major asset group into its own clearly focused public company.
NYSE:GBL) today announced the initial public offering of common shares of The Gabelli Global Deal Fund, a new closed-end fund which will seek to achieve its investment objective by investing primarily in announced merger and acquisition transactions and, to a lesser extent, in corporate reorganizations
involving stubs, spin-offs and liquidations.
368, issued in September 2005, provide taxpayers flexibility in satisfying the continuity of interest (COI) requirement for certain corporate reorganizations
Participants heard an update on interest deductibility from Paul Lynch, Director of CCRA's Financial Industries Division; a discussion of tax-deferred reorganization with Mark Symes, Manager of CCRA's Corporate Reorganizations
Section; and practical issues and solutions in transfer pricing by Mara Praulins, Director of CCRA's International Tax Operations Division.
McLaughlin concentrates his practice in the federal taxation of international mergers, acquisitions, and corporate reorganizations
, as well as all aspects of international tax planning.
The company moved to Tyler, Texas in 1997 and continues to produce conferences to bring together professionals involved in the Distressed Investing Market, Corporate Reorganizations
, Healthcare M&A, Physician Ventures, and Oil & Gas industries.
he IRS has issued important final regulations that provide guidance on the satisfaction of the continuity of interest (COI) and continuity of business enterprise (COBE) requirements for corporate reorganizations
23, 1998, the IRS issued final regulations on the satisfaction of the continuity-of-shareholder-interest (COSI) and continuity-of-business-enterprise (COBE) requirements for corporate reorganizations
The office's core practices include: general corporate transactions including mergers & acquisitions, private equity transactions, corporate restructurings and joint ventures; commercial law including competition law matters, distribution and licensing; labor law, with a particular emphasis on large corporate reorganizations
and litigation; tax including international taxation of companies and individuals, tax structuring of corporate transactions and investment funds, and personal tax planning; and commercial litigation including appearances before various French courts and international arbitration tribunals and acting as "instructing solicitor" in cases before courts and jurisdictions in which the firm is not admitted.
Since the Supreme Court's decision, there has been considerable concern that IRS personnel would interpret INDOPCO as requiring the capitalization of expenditures unrelated to corporate reorganizations
that have customarily been regarded by taxpayers as currently deductible.
These transactions, in the fields of corporate finance, municipal finance, mergers & acquisitions, corporate reorganizations
, and venture capital total several billion dollars in aggregate value.