The purpose of this requirement was to prevent a section 20 subsidiary
from being able to leverage itself more than, and gain a competitive advantage over, its independent competitors by trading on the reputation of its affiliated bank.
381, a Swiss parent corporation owned all of the stock of both its Netherlands Antilles subsidiary
and its U.
as tracked in Dialog Information Service's Disclosure Database, are reported as having at least one subsidiary
The cumulative 2007 forecasted revenue of the three subsidiary
operations is $80 million.
Because no common links existed, the individual subsidiary
spokes were not sufficiently linked together by the contribution and dependency rim to create a single, integrated wheel of unity.
Such synergies cannot occur if the model of the holding company is one in which the parent is just, in effect, a portfolio investor in its subsidiary
Under the current system, the effect of section 1503(e) is limited to recomputing the basis of the subsidiary
whose stock is sold.
must be structured so the REIT owns less than 10% of the subsidiary
's voting stock, either through nonvoting common stock or a combination of nonvoting preferred stock and debt.
First, the independent listing creates a dedicated public capital structure to support next round financing necessary to continue growing the subsidiary
and developing its emerging technologies.
A group member recognizes a loss on a disposition of subsidiary
-member stock that is duplicative of the subsidiary
member's inside loss, the subsidiary
remains a group member and the group subsequently recognizes the subsidiary
member's inside loss.
This proposition can most easily be accepted in the case of dividends because such income can be directly traced to the earnings of the subsidiary
and, unlike interest, the parent is not required to furnish consideration in addition to its capital contribution.
In letter ruling 9133004, a technical advice, the finance subsidiary
obtained funds from the foreign parent via a capital contribution and from proceeds derived from the sale of debentures.