When this is coupled with the ability to treat
stock acquisitions as asset purchases under federal tax law, a basis step-up is achieved.
The rolling
stock acquisitions are to be conducted in five initiatives:
The First Circuit rejected Recovery's argument that section 197(d)(1)(E) applies only to
stock acquisitions considered substantial.
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.
338(h)(10)-1T, effective for
stock acquisitions occurring after July 8, 2003.
stock acquisitions will be taken into account in determining whether a tainted increase in U.
197 treats
stock acquisitions and redemptions similarly.
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.
Further, for both
stock acquisitions and excess distributions, all members of a consolidated group are treated as one taxpayer by Sec.
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.
