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901 (m) provides that "in the case of a 'covered asset acquisition,' the disqualified portion of any foreign income tax determined with respect to the income or gain attributable to the relevant foreign assets ...
Treasury Regulations section 1.1060-1(c) describes the asset classes that are used to allocate the total consideration paid in a business combination structured as an asset acquisition. Basically, section 1.1060-1(c)(2) refers to the same asset classes described trader the IRC section 338 purchase price allocation regulations, but section 1.1060-1(d) also provides a simple, but informative, example of an IRC section 1060 purchase price allocation.
This is in addition to the potential benefit of getting a tax deduction, specifically for asset acquisitions or stock purchases treated as asset acquisitions.
This interdependence could expose the Fed to political pressure to make undesirable concessions with respect to its asset acquisitions in return for support on other matters.
Mandel Resnik, established in 1977, is distinguished for its breadth of experience and capabilities relating to the acquisition, operation and disposition of real estate and the structure of real estate related transactions, cooperative and condominium law, its counsel in stock and asset acquisitions and advice in strategic acquisition, expansion and divestiture programs; and its representation of clients in matters of litigation including shareholder and partnership disputes, employment and discrimination actions, insurance coverage issues, and a wide range of real estate related matters.
Also, asset acquisitions should be well planned to ensure the election is helpful.
These type of transactions became known as "tainted asset acquisitions." Certain asset acquisitions made in the ordinary course of business or assets acquired by a purchaser that would not result in a stepped-up basis in the hands of the purchaser are excepted from the consistency rules and will not result in a tainted asset acquisition.
[section] 1.338-4(g) applies the consistency rules to asset acquisitions from nonconsolidated subsidiaries that are part of an affiliated group.
The revolving credit facility provides the company with up to USD15m, subject to borrowing base requirements, to fund its senior debt and equity portion of distressed asset acquisitions as well as for additional working capital.
This rule requires a dollar-for-dollar reduction in the dollar limit for asset acquisitions above $200,000.
It also provides guidance for balance sheet reporting of general long-term capital debt - liabilities that result from capital asset acquisitions or debt financing of certain nonrecurring projects or activities that have long-term economic benefits.