Whether a taxable transaction
structure would actually result in a step-up or step-down in tax basis.
For example, if a taxable transaction
is assumed, there would be no deferred taxes included as the net assets would have tax basis consistent with book basis.
2 percent represents an increase in actual taxable transactions
, while smaller increases represent a decrease in taxable transactions
However, because WFOE's immediate parent company has changed, this reorganization would be considered a taxable transaction
for Chinese capital gain tax purposes.
This section provides that, if Distributing acquires stock of Controlled by reason of any transaction that occurs within five years of the distribution of Controlled stock and that is a taxable transaction
, such acquired stock will not be treated as stock of Controlled, but instead it will be treated as other property (i.
355 split-up despite the fact that C was acquired in a taxable transaction
within the prior five years.
For example, if a distributing corporation acquired all of a controlled corporation's stock in a taxable transaction
that qualified as an expansion of the distributing corporation's existing trade or business under the SAG regime, and later distributed all such stock within five years of the acquisition in an unrelated transaction, the distribution would satisfy the active trade or business requirement but could be fully taxable under the hot stock rule.
The Trust believes that its liquidation is a taxable transaction
Normally, the forgiveness of debt by a creditor would be a taxable transaction
For example, assume that a foreign parent sells the stock of a domestic corporation to a third party in a taxable transaction
and that the domestic corporation has never held any U.
For purposes of comparison, to have achieved an equivalent amount in a taxable transaction
, Kraft would have needed to receive approximately $4.
In the past two years, the IRS issued two notices, Notices 2006-85 and 2007-48, dealing with two different versions of the transaction and generally treating repatriation of a foreign subsidiary's earnings as a taxable transaction