In this situation, stock redemption at the death of a shareholder may be treated as a dividend distribution, rather than as a capital transaction, due to the family attribution rule
, which causes untold problems for the estate.
7) If stock is deemed to be owned under another attribution rule
, however, the ownership can be reattributed to another family member.
exempt application of JSA attribution rule
in case of existing agreements.
Halpern acknowledged Holmes' reading of the regulation for other types of custodial accounts, but wrote that because of an IRA'S special tax treatment, regarding it in such a fashion "utterly subverts the rationale for the attribution rule
in the regulation.
David Honig, President of the Minority Media and Telecom Council, sent a letter to the FCC, supporting the attribution rule
waiver request for the Marshall-Nexstar proposed JSA.
whether the percentage under a particular attribution rule
is "equal to" or "greater than.
FX directly owned all of the outstanding stock of FY, and FX was deemed to own all the outstanding stock of DX by operation of the attribution rule
of IRC Sec.
In it, the Commission adopted an attribution rule
for television joint sales agreements (JSAs), establishing that same-market television JSAs for more than 15% of the weekly advertising time for the brokered station are to be counted toward the brokering station's ownership totals, just as the Commission has long done with respect to radio stations.
318(a)(3)(C) attribution rule
, and the issue of how to define a related person for purposes of the CFC look-through rule is not addressed.
Third, the House bill modified the attribution rule
for purposes of determining whether an acquisition has occurred.
This proposal would not have to replace the Commission's plan to treat JSAs and SSAs as attributable, but would work to obtain a waiver of the attribution rule
for the JSA or SSA operator.
Without providing any (1) direct evidence that the long-standing ownership attribution rule
for television JSAs negatively affects consumers or the public interest or (2) cost-benefit analysis of its proposed rule change, the Department nonetheless urges the Commission to change established Commission policy and adopt a bright-line rule that would "treat any two stations participating in a JSA (or agreement similar in substance to a JSA) as under common ownership.