68), students' preferred
perceptions of the learning environment were lower than the actual occurrence, albeit to a limited degree.
Where a company is unable to borrow additional funds or issue new debt securities--whether because of concerns over the effect on credit ratings, debt covenant restrictions, or regulatory requirements--and does not wish to dilute earnings per share by issuing additional common shares, a preferred
share issuance is the only viable course.
Applying these same factors to the preferred
securities, the Service determined that, had the corporation issued the preferred
securities directly, they would have been debt for Federal income tax purposes.
All in all, that makes preferred
securities a solid bet for individuals seeking a steady income stream and better-than-average dividends.
Chapter 14 was proposed as an addition to the IRC that would provide a special value for the retained preferred
stock solely for the purpose of valuing common stock sold or given in a freeze transaction.
Under section 351(g)(2)(A), "preferred
stock," which is defined under section 351(g)(3) as "stock which is limited and preferred
as to dividends and does not participate in corporate growth to any significant extent," is treated as NQPS if any of the following criteria is satisfied:
The convertible preferred
leveraged ESOP apparently is becoming the predominant form of new ESOPs.