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.
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?
Further, for both
stock acquisitions and excess distributions, all members of a consolidated group are treated as one taxpayer by Sec.
