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
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.
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.