One common type of debt issued (especially by closely held
entities) is debt with an equity kicker, such as a warrant.
* WHEN A CLOSELY HELD
CORPORATION IS A MAJOR marital asset, divorcing spouses typically agree the corporation should be 100% owned by the spouse who is active in the business.
Controlling families exist widely in both publicly traded stocks and closely held
stocks and have been shown to be an important corporate governance mechanism (e.g., Anderson and Reeb, 2003; Li and Srinivasan, 2011).
corporations who are unjustifiably denied their
And by extending the changes to closely held
for-profit employers that were exempted by the recent Hobby Lobby Supreme Court decision, the HHS proposal actually reduces the "scope of religious freedom," he said.
To operate under these relaxed rules, some states require the corporation both qualify as a closely held
corporation (typically less than 50 shareholders) and elect "statutory close corporate" status.
"The more closely held
the company, the more likely the owners have most of their wealth tied up in their business, which can create both a personal and a corporate financial crisis," he adds.
They are all closely held
corporations, and as such, their shareholders may have fiduciary duties to each other that shareholders of publicly traded corporations do not have.
1.197-2(h)(2)(i) would appear to subject personal intangibles (in existence during the transition period) to the antichurning rules in a situation in which personal intangibles are sold to a closely held
C corporation as part of a sale of the C corporation to an unrelated third party.
When cash is transferred to a closely held
corporation, is the transfer a loan or a capital contribution?
It annually serves more than 1,000 clients ranging from closely held
companies to Global 500 corporations.
* Purchase and Sale of Closely Held
Businesses: Advanced Real World Tax Strategies (PSAS)