Finally, since Congress intended to require gain recognition only where a taxpayer is exchanging risky instruments for more secure instruments, gain recognition is not required under section 354, 355, or 356 under the following circumstances: (1) certain exchanges of preferred stock
for comparable preferred stock
of the same or lesser value;(4) (2) an exchange of preferred stock
for common stock; and (3) certain exchanges of debt securities for preferred stock
of same or lesser value.
None of the newly issued regulations shed any light on some important issues surrounding nonqualified preferred stock
and how that stock will be treated by other sections of the Code.
Study legislation to target abusive freeze transactions such as manipulation of investment instruments, lapsing rights, unrealistic buy-sell agreements and valuation of preferred stock
upon a subsequent gift of the preferred stock
, or death of the preferred stockholder, inconsistent with the valuation of the preferred stock
at the time of the freeze.
The employer may redeem the preferred stock
with cash or common stock at a price equal to the initial value of the preferred stock
3689 per share representing the dividend payment originally due November 15, 2006, was declared on the outstanding Series C Preferred Stock
, payable February 15, 2007, to shareholders of record at the close of business on February 5, 2007.
The company may, in the future, purchase additional shares of its preferred stock
, although the company and its affiliates are prohibited from purchasing shares until at least ten business days after December 19, 2006.
The Preferred Stock
called for redemption is convertible until the close of business (5:00 p.
The general expectation of stable dividends for a preferred stock
or comparable hybrid means that the volatility should be much lower than that of common stock, except in the circumstance when the issuer approaches insolvency.
As a condition to the closing of the Preferred Stock
Transaction, Viking has completed a conversion of certain outstanding Convertible Notes in the aggregate principal amount of $4,750,000.
Prior to the Redemption Date, holders of Series A Preferred Stock
may elect to convert such shares into shares of Patapsco Bancorp, Inc.
00 for each share of Series D Preferred Stock
redeemed, plus accrued dividends of $0.
The financial restructuring had two components: a May 2002 extinguishment of certain junior debt (the "May 2002 Exchange Transaction"); followed by a November 2002 exchange of Series C Preferred Stock
and redeemable common stock purchase warrants for its Series A and Series B Preferred Stock
, warrants for the purchase of shares of Series B Preferred Stock
, common stock warrants and shares of its common stock (the "November 2002 Exchange Transaction").