Since Form 8288-B requires a TIN, a transferor and/or transferee
who does not qualify for an SSN may apply for an ITIN by attaching Form 8288-B to Form W-7, Application for IRS Individual Taxpayer Identification Number.
The Senate version of the IRS Restructuring and Reform Act of 1998 included proposed new section 357(c)(4), which would provide that in the case of the transfer of property subject to a nonrecourse liability, the transferee
is treated as assuming with respect to each property only a "ratable portion" of the liability.
Thus, the effect upon transferee
stock basis may form part of the calculus in determining whether to elect under Sec.
As a general matter, if a partnership properly maintains capital accounts under the section 704(b) safe harbor regulations,(28) a transferee
's interest in the partnership's previously taxed capital is the amount of the transferee
's capital account,(29) decreased by any remaining built-in gain (and increased by any remaining built-in loss) that would be allocable to the transferee
under the principles of section 704(c)(1)(A) if the partnership sold the contributed property at the time of the transfer of the partnership interest.
The IRS countered that the notices of transferee
liability were timely because the 2005 petition constituted a "proceeding in respect of [SCC's] deficiency" that suspended the limitation period under Sec.
Thus, if an interest in the partnership were transferred to a corporation or partnership, the "look through" rule would apply, so that the transferee
would be deemed to hold $3 million of Listed Assets and $2 million of other assets.
PorchLight Rental strategically works within the stipulations of relocation policies to assist transferees
with their rental housing needs.
Rather, it looked first at whether a state law basis existed for transferee
liability for the taxpayers and then at whether the taxpayers were transferees
for purposes of Sec.
It is becoming more frequent that a corporate transferee
is looking to rent.
A number of transferees
have regrettably engaged in aggressive behaviour over the weekend at the Manus Regional Processing Centre and that protest action is ongoing.
When a loan transfers with an active complaint, there must be a process to ensure that the complaint is resolved or handed off to the transferee
in such a way that it is tracked through to resolution.
NOTICE IS HEREBY GIVEN that, by application dated 23 May 2014, Harworth Insurance Company Limited (Transferor) and Royal & Sun Alliance Insurance Plc (the Transferee
), applied to the High Court of Justice of England and Wales, for amongst other things, an order under Section 111(1) of the Financial Services and Markets Act 2000 (the Act) sanctioning an insurance business transfer scheme (the Scheme) providing for the transfer of insurance business written by the Transferor (the Transferring Business) to the Transferee
and for an order making provision under Section 112 of the Act.