In essence, owning
a home builds stronger families.
Here, FP is treated as owning
100% of J1's stock, under Sec.
Although the investment adjustment rules generally maintain the original balance between the net asset basis of a subsidiary (including its NOL carryovers) and the owning
member's stock basis, section 312(k) produced glaring disparities between outside stock basis and inside net asset basis before the enactment of section 1503(e) by the 1987 Act.
1298(a)(2)(B), however, no such 50% threshold exists for a person owning
stock in a PFIC.
87-90, the IRS confirmed that the parent of a wholly owned subsidiary is treated as owning
all of the subsidiary's assets for Sec.
Elgin decided in his 20s, while holding down a service job at the local transit authority, that there was a better future for him in owning
his own business.
No doubt, owning
a cable network comes with a myriad of difficulties when trying to add original programming to the mix.
6038(e)(2) defines "control" as owning
"stock possessing more than 50% of the total combined voting power of all classes of stock entitled to vote, or more than 50% of the total value of shares of all classes of stock"
(An "allied" member is a principal of the firm owning
voting stock.) This means the African American principals with voting stock in First Harlem joined the exchange "and the walls came tumbling down."
Scot: As you know, there is no prohibition against an S corporation owning
stock in a foreign corporation; however, that S corporation may not make a QSSS election for the foreign subsidiary.
The shareholders of the second corporation end up owning
more than 50% of the first corporation's outstanding stock.