In a second terminating
event, the trust that had made the QSST election failed to distribute all of its income.
Phillips-Van Heusen said it was terminating
the lease because the outlet mall had not lived up to a requirement to keep at least 70 percent of the available floor space leased.
The parent distributed its stock in the QSub to its shareholders, thus terminating
the QSub election.
On October 21, 2005 Young-Shannon notified MacMillan that it was terminating
the option agreement.
The second type of agreement, the "Old Redemption Agreement" only applied to two senior firm members and required them to sell their shares back to the firm at book value on a terminating
event, determined as of the last day of the firm's prior tax year.
If the Mine Purchase does not close by December 1, 2005, either Apollo or Jipangu may terminate the agreement, provided that the terminating
party has not breached the agreement in a manner that has prevented the closing.
The Service concluded that (1) the LLP would be an eligible S corporation, (2) the partnership agreement did not create a second class of stock terminating
the election and (3) the LLP could make a QSub election for the S corporation.
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The ruling held that gain or loss from terminating
the swap is neither spread over the entire term of the debt instrument nor accounted for entirely in the termination year.
New Business Unit is First to Offer Comprehensive Legal, Compliance, and Administrative Support for Plan Administrators in Lengthy, Difficult Process of Terminating
Employer filed Form 5310, Application for Determination for Terminating
Plan, and the IRS issued a favorable determination letter.
SPACEHAB has entered into a rights agreement amendment, terminating
the agreement effective July 13, 2005.