resulting

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See: ancillary, derivative, ensuing, subsidiary

References in periodicals archive ?

For mergers, the statute looks to the partners who hold a majority interest in the resulting partnership; for divisions, the statute looks to the partners who held a majority interest in the prior partnership.

708(b)(2)(A) provides that the resulting partnership is a continuation of the merging partnership whose partners own aggregate interests of more than 50% in the resulting partnership's capital and profits; all other merging partnerships are deemed terminated.

If the resulting partnership is a continuation of one of the merging partnerships (the continuing partnership), the resulting partnership and the continuing partnership are considered one and the same for Federal income tax purposes.

708(b)(2)(B) provides that any resulting partnership is deemed a continuation of the prior partnership, unless the resulting partnership's partners owned aggregate interests of 50% or less in the prior partnership's capital and profits.

However, if each of the ABCD partners owned a 25% interest in ABCD, all of the resulting partnerships would be treated as new.

Any resulting partnership deemed a continuation of the prior partnership must file a return for the latter's tax year.

Assets-over form: The noncontinuing merging partnerships contribute all of their assets and liabilities to the resulting partnership in exchange for resulting partnership interests.

Merger and division prop. regs

Telefonica Moviles's stake in the resulting company, Telefonica Moviles Peru, S.

On the other hand, improvements in credit scoring systems for contract customers have led to a reduction in churn rates in this segment compared to previous quarters, resulting in positive net adds in the contract segment for the first time this year.