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It indicated that a stock acquisition followed by state law dissolution (as opposed to conversion) would not qualify as a statutory merger for the same reasons.
The merger of a corporate partner into a partnership resulting in the corporate partner going out of existence can qualify as a statutory merger or consolidation under Regs.
Moreover, the deemed transfer of the former QSub assets in exchange for stock in the newly-formed corporation does not cause the transaction to fail to qualify as a statutory merger or consolidation.
Except for construction, architectural, and engineering services, gross receipts derived from the performance of services do not qualify as DPGR.
31) Gross receipts related to embedded services or non-qualifying property that meet one of these five of the exceptions can qualify as DPGR.
32) In two of the examples, receipts allocable to separately stated training services and delivery services do not qualify as DPGR.
Jessica's travel expenses to attend the Florida seminar do not qualify as educational assistance under Sec.
Supervision by managers other than first-line managers does not qualify as direct supervision, even if those managers are qualified research scientists themselves.
Interviews with technical personnel who have been fully educated about the tax requirements regarding activities that qualify as research or experimentation should be performed as soon as the need for the information is discovered, and should routinely be performed when any such personnel leave the taxpayer's employment.
678 trusts generally qualify as S shareholders provided the entire trust is treated as a grantor trust.
In Letter Rulings 8827023, 8809043, 8805032, 8613054 and 8342088, the IRS ruled that Crummey trusts qualify as S shareholders, provided no contribution is made to the trust that is not subject to the Crummey power, and the grantor is not deemed to be the owner of the trust under Sec.
The simplest solution may be to use the S stock to fund the marital trust, since it generally is easier to structure a marital trust to comply with the QSST requirements or to qualify as a Sec.