Spin-offs and leverage
Article Abstract:
Cash transfers in the form of loans between parent corporations and subsidiaries made prior to spin-offs which result in separating the entities should not in most cases cause IRC section 355 spin-offs to be taxable. Six requirements or tests under this section must be met to avoid realization of gain. Not meeting the devise test is the cause of taxability and not the method of funding by debt cancellation, cash balances, or new debt.
Publication Name: Taxes: The Tax Magazine
Subject: Business
ISSN: 0040-0181
Year: 1997
User Contributions:
Comment about this article or add new information about this topic:
Convertible debt: conversion as a bargain purchase
Article Abstract:
The holder's exercise of a conversion right adhering to a convertible debt instrument should be considered a purchase/sale with no corresponding capital gain or loss. The instrument's issuer would recognize the gain or loss under this theory. Tax-free exercise of conversion privileges would ensure all debenture conversions into stock, including the exercise of either conversion rights or options, would receive the same tax treatment.
Publication Name: Taxes: The Tax Magazine
Subject: Business
ISSN: 0040-0181
Year: 1995
User Contributions:
Comment about this article or add new information about this topic:
Corporate combining transactions
Article Abstract:
Corporate combinations designed to eliminate stock gain include downstream or upstream mergers, inversions, triangular reorganizations, and creeping transactions. These corporate combining transactions may create tax problems under the regulations governing IRC Section 337(d). The IRS must consider the pros and cons of recognizing gain or loss in combining transactions in creating guidelines to address these problems.
Publication Name: Taxes: The Tax Magazine
Subject: Business
ISSN: 0040-0181
Year: 1995
User Contributions:
Comment about this article or add new information about this topic:
- Abstracts: Transaction costs and slaughter cattle procurement: processors' selection of supply channels. Information asymmetry and the role of traceability systems
- Abstracts: Spreading the net. Beer money: it's decision time - what share will we put in our single-company Pep? Smaller companies roller coaster fun: investing in smaller companies can be rewarding but private investors must watch out for the pitfalls
- Abstracts: Jumping into profit. Cloud Base: confusion in an instant. Toad: toys for boys
- Abstracts: Physiological and subjective measures of workload when shovelling with a conventional and two-handled ('levered') shovel
- Abstracts: The loan arrangers. In succession. Court-appointed conflicts