References in periodicals archive ?
An example in the proposed regulations provided COI was not satisfied when the issuing corporation stock was less than 30% of the total consideration provided to target shareholders in the transaction.
Some companies might want to consider issuing debt with warrants attached This would allow them to obtain lower interest rates than otherwise available.
Hence, in addition to issuing revised regulations, the IRS should consider modifying its approach to the examination of research credit activities.
All three types have a common element: They permit the Service to assess an income tax deficiency (or abate an overassessment in the case of a refund) without issuing a statutory notice of deficiency.
Brown reported that, in response to the IRS Notice requesting input from taxpayers and practitioners about the 2000 Guidance Priority List, the IRS has received more recommendations for issuing guidance than it can hope to complete.
During the corporation's five most recent tax years ending before the date of the loss in question, more than-50% of its gross receipts were from- sources other than royalties, rents, dividends, interest, annuities, and sales or exchanges of stocks and securities (there is an exception to this provision if the issuing corporation's deductions exceed income).
In many respects, issuing public guidance on involuntary, Service-initiated changes in accounting methods is navigating a course in uncharted waters.
This limitation is prorated for loss corporations issuing stock in short tax years.
Are they discussing the IDRs with you before they are issuing them?
Yet another possibility is to recast the transaction so the debtor, not the holder, is treated as acquiring its debt from the unrelated holders for the related holder's debt, which the debtor acquires from the related holder by issuing new debt.