The First Circuit rejected Recovery's argument that section 197(d)(1)(E) applies only to stock acquisitions
338(h)(10)-1T, effective for stock acquisitions
occurring after July 8, 2003.
In fact, the company has changed MIS systems at least twice during that period, has outsourced its payroll function, has used two different stock transfer agents, has negotiated several third-party administrator contracts for health insurance and workmen's compensation, has adopted and eliminated numerous sales incentive programs, has made several stock acquisitions
, and has never filed an unclaimed property report.
On the occasion of the corporate split, persons holding Hitachi's stock acquisition
rights will not be granted Hitachi Industrial Equipment Systems's stock acquisitions
rights in place thereof.
197 treats stock acquisitions
and redemptions similarly.
will be taken into account in determining whether a tainted increase in U.
Further, for both stock acquisitions
and excess distributions, all members of a consolidated group are treated as one taxpayer by Sec.
Even if there is agreement new basis is appropriate for majority stock acquisitions
, does a secondary offering, an initial offering or the exchange of a majority of an entity's stock in the market over a short time qualify?
Our ability to execute this substantial acquisition in Brazil with cash should send a strong signal to the market regarding NewMarket's commitment to shift away from stock acquisitions
172(h) which in general disallows the carryback of NOLs following certain stock acquisitions
, does not apply for two reasons.
The Company believes that (i) in contrast to stock acquisitions
through a registered public tender offer, which ensure transparency with respect to information disclosure and fairness among shareholders of the target company, the said stock acquisition
by Livedoor using ToSTNeT-1 (the "Acquisition") is far from a transparent and fair transaction for shareholders of the Company, since control premiums for the Acquisition were paid only to some of the shareholders of the Company, and that (ii) the Acquisition is at least against the purposes of the Japanese tender offer regulations and, moreover, there is doubt about its legality.
However, the RRA eliminated this exclusion for stock acquisitions
occurring after Oct.