In Letter Ruling 201341004 (the facts and steps have been simplified for purposes of this item), a wholly owned subsidiary (Subsidiary) of a parent corporation
(Parent) established a grantor trust under Sec.
Failure to adhere to these could result in creditors being able to "pierce the corporate shield" and hold the parent corporation
accountable for the debts of the subsidiary.
f) The subcontractor can issue an invoice to the parent corporation
for the testing service, and not include GST under the zero-rated provision of subsection 4(a) of Part V of Schedule VI of the ETA.
Although the preceding discussion suggests that revenue recognition for the parent corporation
man, not occur until the resale of the counterpurchase goods, transactions must be recorded a each exchange that led to the final sale For the subsidiary (assuming a separate entity), the countertrade transactions are a series of "business as usual" entries The subsidiary would recognize revenue at the point of sale for the reasons state earlier.
12, 1990), the New York State Tax Appeals Tribunal determined that a corporation was involved in a unitary business with its parent, a holding company, when the parent corporation
lent money to the subsidiary, was involved in obtaining outside financing for the subsidiary's business activities, had no employees of its own, and relied completely on the subsidiary's facilities and employees.
2), a parent corporation
, to deduct from its Part 1.
Parent-subsidiary controlled group definitions and tests: A parent-subsidiary group, one of the three types of controlled groups, consists of a common parent corporation
connected with one or more other corporations through stock ownership to form a chain (or chains) of corporation.
The court stated that a parent corporation
using a subsidiary for transaction of the parent's business (as distinct from the subsidiary's business) may be held liable for the acts of the subsidiary under general agency principles.
Decisions made by the parent corporation
with respect to its customers and credit insurance offerings, which include a marketing focus on high credit-quality small businesses and the replacement of traditional credit insurance products with a bank debt waiver and cancellation program, will continue to impact the company's ability to expand its business.
2268 (1994), held worldwide combined reporting to be constitutional as applied to unitary groups whether the parent corporation
was domestic or foreign.
1504(a) as one or more chains of includible corporations connected through stock ownership to a common parent corporation
that is also an includible corporation, provided certain stock ownership requirements are met.
Arctic Slope Regional Corporation, ASRC Federal's parent corporation
, is owned by more than 9,500 Inupiat Eskimos primarily located along Alaska's North Slope.