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Also, mutual holding companies aren't answerable to the market on a quarterly basis to the same extent as stock companies.
172--What are the holding periods permitted for merchant banking investments?
To defeat the tax agency's argument that the structure is merely a tax gimmick without substance and that the debt owed by Target to Holding should be disregarded, Target and Holding must be able to demonstrate that the debt had the form of a debt instrument, that the parties intended that it be a debt instrument, and that economically the instrument was a debt.
I simply want the freedom to decide when holding hands in church is right for me when it will be a grace and not an aggravation.
The real benefit of the expansion of the AJCA provisions to depository holding companies is for existing C corporations, with IRA shareholders, that are considering electing S status.
The GLB Act allows financial holding companies--which are bank holding companies whose depository institutions meet specified capital, management, and, for insured institutions, Community Reinvestment Act requirements--to acquire shares, assets, or ownership interests in any type of nonfinancial company.
31) The parties stipulated that the taxpayer occasionally sold assets of the type in question, but the court pointed out that its purpose in holding the assets was to produce petroleum and not to sell the property.
After the long-term holding period is met and development is ready to begin, the partnership sells the property to a second entity set up as a commonly owned S corporation.
10 means the transference of the subsidy to a wider range of financial businesses, producing distortions in the competitive balance between those latter units that receive a subsidy and identical units that do not--whether those units are subs of holding companies or totally independent of banking.
Under paragraphs (e), (f), (g) and (h) of this section, transactions in certain property give rise to gain or loss included in the computation of foreign personal holding company income if the controlled foreign corporation holds that property for a particular use or purpose.
The bill prohibits joint marketing of the products of the banking organization and the firms in which the bank holding company invests.