* Low inertia--due to the low moment of inertia of the rotating parts in the hydraulic motor, the start-ups, accelerations, decelerations, stops and reversals can be smooth and easily controlled
As another example, a non-binding letter of intent (or similar communication) that sets forth in sufficient detail the manner in which a subsequent change in control might occur following a distribution of a controlled
company could constitute a plan for purposes of section 355(e).
First, it reinstated the old definition of control; thus, the shareholders of Distributing must own stock with 80% or more of the voting power and at least 80% of the total number of shares of all other classes of Controlled
For purposes of paragraph (b)(1) of this section, any shares, assets, or ownership interests previously owned or controlled
, directly or indirectly, by a financial holding company under any other provision of the Federal banking laws that imposes a limited holding period will if acquired under this subpart be considered to have been acquired by the financial holding company under this subpart on the date the financial holding company first acquired ownership or control of the shares, assets or ownership interests under such other provision of law.
study of the influence of segregation of tuberculous patients for one year on the attack rate of tuberculosis in a 5-year period in close family contacts in South India.
It is advantageous to select the fewest number of indicative parameters that can be controlled
and provide reliable data.
However, in what came to be known as a "Morris Trust transaction," the Service did not require gain recognition if either Distributing or Controlled
were subsequently acquired in a tax-free transaction.
* The acquisition of stock in a controlled
corporation by reason of holding stock in the distributing corporation;
Actor Darren McGavin held on to his $218.98 a month rent controlled
apartment although he lived most of the time in his Beverly Hills mansion.
They also reportedly offer 20-40% lower power consumption, smooth flow passages with reduced shear, and ability to be controlled
with a single setpoint.
482 to require that consideration for intangible property transferred in a controlled
transaction be commensurate the income attributable to it.
Section 355 of the Internal Revenue Code of 1986 provides for tax-free treatment of the separation of one or more active businesses through the distribution by a corporation (Distributing) of the stock or securities of a controlled
), either existing or newly formed by the transfer of assets to it, by Distributing.