If the redemption
did not qualify as an exchange under Sec.
The distribution is in redemption
of a noncorporate shareholder and is in partial liquidation of the distributing corporation.
He stresses that for a student to make a favorable impression on him and succeed as a Redemption
student, the student must want to make something of his life.
8 million accounting charge in connection with the preferred redemption
there is no impact to the company's previously announced funds from operations guidance for 2004.
Subsequently, Joann filed a refund claim on the grounds the redemption
was not taxable to her under section 1041.
301(b)(1) applies only when redemption
results "in a meaningful reduction in the shareholder's proportionate interest in the corporation.
in this category must meet certain mathematical tests.
Holders of the Preferred Securities should complete the appropriate instruction form for redemption
or conversion, as applicable, pursuant to The Depository Trust Company's book-entry system and follow such other directions as instructed by The Depository Trust Company.
1980), aff'g 70TC 715 (1978), in which the taxpayers prevailed because corporate obligations under a complete redemption
did not (1) create a proprietary interest, (2) become subordinate to general creditors' claims or (3) retain an interest other than that of a creditor.
a mandatory redemption
totalling SEK 7 billion, which is equivalent to SEK 35 per share.
Typically, the parties have resolved the first issue by negotiating a stock transfer or stock redemption
in their divorce agreement.
Quinlivan, section 302(b)(3) also applies to a part sale, part redemption
transaction if, as is typical, the steps are part of an integrated plan; in these cases, the step-transaction doctrine treats the steps as a unit for purposes of determining eligibility for section 302(b)(3) treatment.