The foreign holding company would have become a domestic corporation, assuming there would be no substantial business activity in its country of incorporation, because the foreign parent's 85% of the foreign holding company's stock would have been disregarded as stock held
by an EAG member.
This event will be held
at the Rainbow Room at 30 Rockefeller Plaza in New York City.
i) Acquired by a financial holding company from a company in which the financial holding company held
an interest under this subpart will be considered to have been acquired by the financial holding company on the date that the share, asset or ownership interest was acquired by the company; and
The taxpayer petitioned the Tax Court, which held
Consequently, we proposed a 50 percent capital requirement on portfolio equity investments held
under any authority at any location in a bank holding company.
A number of courts have held
that the transactional test is the sole test and that the functional test does not exist.
Accounting for foreclosed assets held
for sale after foreclosure.
The event will be held
at Pier 60, Chelsea Piers at 6 p.
The more frequent the sales, the more time and effort spent on sales; the shorter the period the property is held
, the stronger the case for dealer status (see Phelan, TC Memo 2004206, discussed in Sartain, Tax Clinic, "Capital Gain on Development Property" TTA, December 2004, p.
ceremony will be held
at Pierce Brothers Valhalla Cemetery, 10621 Victory Blvd.
DeMatteo most recently held
the position of Vice President/Asian Development for Sunrise Medical.
The agreement provided that all documents would be held
in escrow until July 11, 1997.