Worldwide Facilities Acquires
Connecticut's Tennant Risk Services
2001 - Alliant Techsystems (ATK) acquires
Thiokol for $2.9 billion
North Korean willingness to sell complete systems and components has enabled other states to acquire
longer range capabilities."
A financial holding company may not under this subpart acquire
or control assets, other than debt or equity securities or other ownership interests in a company, unless:
1987 - Acquires
Alabama Ductile, a high-volume ductile iron foundry in Brewton, Alabama.
Alera Group did not acquire
any interest in the firms that are members of The Alliance beyond the previously existing Alera Group firms.
Section 355(e) is especially troubling for public companies effecting a spin-off distribution since neither the distributing nor the controlled companies can predict or control the unilateral, acquisitive actions of another company that may seek to acquire
the distributing or distributed companies or predict or control public trading by shareholders.
Commenter notes, however, that under the exception, a shareholder who acquires
10 percent or more of the voting shares of a company or any affiliate of the shareholder may not merge or combine with the company for five years after the shareholder's ownership reaches the 10 percent level unless the company's board of directors approves the merger or combination.
Consider the example of one corporation ("Holding") that acquires
the stock of another corporation ("Target") for less than (or more than) the historic cost of Target's assets.
Under a domestic ESOP, a company-established trust acquires
employer shares and holds them until employees are ready to take their distributions, which usually occurs at retirement.
However, when the taxpayer acquires
used property, then incurs additional costs to recondition or rebuild it, Temp.
Section 355(e) applies if there is a section 355 distribution that is part of a plan pursuant to which a person or persons acquires
, directly or indirectly, stock representing at least a 50-percent interest in the distributing corporation or any controlled corporation.