Corporations - Second circuit adopts "firm and fixed plan" test for purposes of integration of transactions

Article Abstract:

The Second Circuit court has upheld the ruling of the Tax Court in the Merrill Lynch & Company, Inc., 94 AFTR 2d 2004-6119 (CA-2, 2004), aff'g in part, remanding in part, 120 TC 12 (2003) case. The court observed that cross-chain sales by the subsidiary of Merrill Lynch did not result in dividend income to the subsidiary and did not increase Merrill Lynch's basis in the subsidiary. The court adopted the "firm and fixed plan" test to arrive at the ruling.

Security brokers and dealers, Securities & Commodities Services, Securities, Commodity Contracts, and Other Financial Investments and Related Activities, Securities industry, Merrill Lynch & Company Inc., Sales accounting

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Partnerships - District Court allows shifting of taxable income to foreign partners

Article Abstract:

The court has upheld the transaction of the General Electric Capital Corporation, which entered into a partnership with two Dutch banks to enable it to shift a significant portion of its taxable lease income from their fully depreciated aircraft to its partners. This was the ruling given by the court in the TIFD-III-E, Inc., 94 AFTR 2d 2004-6635 (D.Conn.2004) case.

Commercial Banks, Partnerships, Business Credit Institutions, Banking industry, Commercial finance companies, Partnership, General Electric Capital Corp.

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