332, requiring the parent corporation
to take a carryover basis in the subsidiary's assets pursuant to Sec.
(d) The subsidiary can issue an invoice to the parent corporation
for the testing service (even though the work is outsourced to a subcontractor), and not include GST under the zero-rated provision of subsection 4(a) of Part V of Schedule VI of the ETA.
Under certain possible interpretations of the meaning of "a member's firm," a client that avails itself of any of the services provided by Parent Corporation
would be in one of these forbidden categories.
For instance, this situation can arise when a foreign parent corporation
sells inventory to its subsidiary in the United States (e.g., the U.S.
corporation pays $100 of interest to its Hong Kong parent corporation
, the payment would be subject to U.S.
Persons not obviously connected to the risk, such as real estate brokers, lenders, parent corporations
, purchasers in asset deals, passive lessors and lessees, insurance companies, and officers or other responsible corporate personnel, may be liable as "owners" or "operators" under the statute.
The parent corporation
of First Internet Bank of Indiana, First Internet Bancorp (NASDAQ:INBK) has priced a underwritten public offering of 1,380,000 shares of its common stock at USD20.00 per share, for gross proceeds of USD27.6m, the company stated on Friday.
First BanCorp (NYSE:FBP), the parent corporation
of FirstBank Puerto Rico, has said that it has amended the exchange agreement executed with the US Treasury on July 7, 2010.
For example, a foreign captive may insure the risks of only its parent corporation
, and thus the arrangement may not be treated as insurance for Federal tax purposes.
This revenue recognition option appears most appropriate for the subsidiary located in the soft currency country, but not for the parent corporation
. The soft currency received would be the subsidiary's functional currency and be considered a liquid asset.
Finally, the cash flow of an IS department is its revenue from a single customer--the parent corporation
. This cash flow very rarely decreases; in fact, it increases anywhere from 5 percent to 20 percent annually.