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Comments on final regulations under Section 355 relating to corporate separations. (filed by Tax Executives Institute with Department of the Treasury and ... 25, 1989): An article from: Tax Executive
This digital document is an article from Tax Executive, published by Tax Executives Institute, Inc. on September 1, 1989. The length of the article is 3551 words. The page length shown above is based on a typical 300-word page. The article is delivered in HTML format and is available in your Amazon.com Digital Locker immediately after purchase. You can view it with any web browser.
Citation Details
Title: Comments on final regulations under Section 355 relating to corporate separations. (filed by Tax Executives Institute with Department of the Treasury and IRS on July 25, 1989)
Author: David F. Nitschke
Publication: Tax Executive (Magazine/Journal)
Date: September 1, 1989
Publisher: Tax Executives Institute, Inc.
Volume: 41 Issue: n5 Page: 457-460
Distributed by Thomson Gale
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Sec. 355's expansion exception extended.(tax free spinoff tax guidance): An article from: The Tax Adviser
This digital document is an article from The Tax Adviser, published by American Institute of CPA's on April 1, 2004. The length of the article is 683 words. The page length shown above is based on a typical 300-word page. The article is delivered in HTML format and is available in your Amazon.com Digital Locker immediately after purchase. You can view it with any web browser.
Citation Details
Title: Sec. 355's expansion exception extended.(tax free spinoff tax guidance)
Author: Paul Dailey
Publication: The Tax Adviser (Magazine/Journal)
Date: April 1, 2004
Publisher: American Institute of CPA's
Volume: 35 Issue: 4 Page: 196(2)
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Rev. Proc. 96-30 provides guidance on sec. 355 business purpose.: An article from: The Tax Adviser
This digital document is an article from The Tax Adviser, published by American Institute of CPA's on September 1, 1996. The length of the article is 1639 words. The page length shown above is based on a typical 300-word page. The article is delivered in HTML format and is available in your Amazon.com Digital Locker immediately after purchase. You can view it with any web browser.
From the supplier: The IRS has issued Revenue Procedure 96-30 to provide guidelines for receiving advanced rulings on business purpose evaluations under IRC section 355. When two corporations form a new corporation and distribute the new stock to shareholders, the stockholders and the distributing corporation can receive tax-free treatment under section 355 if a valid business purpose exists for the transaction. The IRS has identified a number of valid purposes and has detailed the evidence that must be presented to substantiate those business purposes.
Citation Details
Title: Rev. Proc. 96-30 provides guidance on sec. 355 business purpose.
Author: Louis A. Panoutsos
Publication: The Tax Adviser (Magazine/Journal)
Date: September 1, 1996
Publisher: American Institute of CPA's
Volume: 27 Issue: n9 Page: 526(3)
Distributed by Thomson Gale
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TRA '97 and Sec. 355. (IRC s. 355): An article from: The Tax Adviser
This digital document is an article from The Tax Adviser, published by American Institute of CPA's on June 1, 1998. The length of the article is 667 words. The page length shown above is based on a typical 300-word page. The article is delivered in HTML format and is available in your Amazon.com Digital Locker immediately after purchase. You can view it with any web browser.
From the supplier: Changes made to IRC section 355 by the Taxpayer Relief Act of 1997 are favorable from the perspective of distributing corporations and shareholders in receipt of distributed controlled corporation shares. Nonrecognition of gain is possible at both levels if four requirements are met. Congress provided this favorable treatment at the same time as it created limitations on other uses of section 355 which could result in corporate level gain recognition.
Citation Details
Title: TRA '97 and Sec. 355. (IRC s. 355)
Author: John Geracimos
Publication: The Tax Adviser (Magazine/Journal)
Date: June 1, 1998
Publisher: American Institute of CPA's
Volume: 29 Issue: n6 Page: 364(2)
Distributed by Thomson Gale
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IRS will not rule that risk reduction alone is a valid business purpose under Sec. 355.: An article from: The Tax Adviser
This digital document is an article from The Tax Adviser, published by American Institute of CPA's on June 1, 1994. The length of the article is 457 words. The page length shown above is based on a typical 300-word page. The article is delivered in HTML format and is available in your Amazon.com Digital Locker immediately after purchase. You can view it with any web browser.
From the supplier: The IRS will not issue letter rulings to sanction transactions that have as their sole business purpose risk reduction because the evaluation of alternatives required in the Internal Revenue Code section 355 business purpose test is too fact-specific. If there are business purposes identified in addition to risk reduction, the IRS will issue a ruling. Taxpayers wishing to receive a ruling on a section 355 transaction should identify additional business purposes, such as a reduction in insurance costs.
Citation Details
Title: IRS will not rule that risk reduction alone is a valid business purpose under Sec. 355.
Author: Richard W. Bailine
Publication: The Tax Adviser (Magazine/Journal)
Date: June 1, 1994
Publisher: American Institute of CPA's
Volume: 25 Issue: n6 Page: 367(1)
Distributed by Thomson Gale
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A step up from Sec. 355?: An article from: The Tax Adviser
This digital document is an article from The Tax Adviser, published by American Institute of CPA's on February 1, 1993. The length of the article is 659 words. The page length shown above is based on a typical 300-word page. The article is delivered in HTML format and is available in your Amazon.com Digital Locker immediately after purchase. You can view it with any web browser.
From the supplier: A step-up in basis, or increase to fair market value can be achieved in split-offs of corporate assets with only one level of tax under IRC 355. The process involves the formation of a controlled corporation through which all transactions are handled between the parent corporation and the stockholder benefitting from the split-off. An example of the process is included.
Citation Details
Title: A step up from Sec. 355?
Author: Robert B. Haran
Publication: The Tax Adviser (Magazine/Journal)
Date: February 1, 1993
Publisher: American Institute of CPA's
Volume: 24 Issue: n2 Page: 99(1)
Distributed by Thomson Gale
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S corporations' practical alternatives to a sec. 355 spin-off.: An article from: The Tax Adviser
This digital document is an article from The Tax Adviser, published by American Institute of CPA's on September 1, 1993. The length of the article is 918 words. The page length shown above is based on a typical 300-word page. The article is delivered in HTML format and is available in your Amazon.com Digital Locker immediately after purchase. You can view it with any web browser.
From the supplier: The creation of a S corporation wholly owned subsidiary under IRC section 355 rules is complex and subjective, generating potential conflicts with the transaction's tax-free status. A S corporation can create a subsidiary without triggering section 355 by making a tax-free property dividend to shareholders who would then contribute it to the subsidiary or by making a cash distribution which would be used by shareholders to purchase subsidiary stock. However, if the fair market value exceeds the corporation's basis in the assets then gain will be generated.
Citation Details
Title: S corporations' practical alternatives to a sec. 355 spin-off.
Author: Ron Kuyath
Publication: The Tax Adviser (Magazine/Journal)
Date: September 1, 1993
Publisher: American Institute of CPA's
Volume: 24 Issue: n9 Page: 559(2)
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INDONESIA: Construction contract award for planned $355,000,000 coal-fired power plant, STEAG AG [Germany] - Order #: 011104.: An article from: WWP-Business Opportunities in Asia & the Pacific
This digital document is an article from WWP-Business Opportunities in Asia & the Pacific, published by Worldwide Projects, Inc. on January 1, 2004. The length of the article is 1263 words. The page length shown above is based on a typical 300-word page. The article is delivered in HTML format and is available in your Amazon.com Digital Locker immediately after purchase. You can view it with any web browser.
Citation Details
Title: INDONESIA: Construction contract award for planned $355,000,000 coal-fired power plant, STEAG AG [Germany] - Order #: 011104.
Publication: WWP-Business Opportunities in Asia & the Pacific (Newsletter)
Date: January 1, 2004
Publisher: Worldwide Projects, Inc.
Volume: 13 Issue: 01
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IRS issues guidance on Sec. 355 active-trade-or-business test.: An article from: The Tax Adviser
This digital document is an article from The Tax Adviser, published by Thomson Gale on January 1, 2007. The length of the article is 1285 words. The page length shown above is based on a typical 300-word page. The article is delivered in HTML format and is available in your Amazon.com Digital Locker immediately after purchase. You can view it with any web browser.
Citation Details
Title: IRS issues guidance on Sec. 355 active-trade-or-business test.
Author: Kirsten Simpson
Publication: The Tax Adviser (Magazine/Journal)
Date: January 1, 2007
Publisher: Thomson Gale
Volume: 28 Issue: 1 Page: 9(2)
Distributed by Thomson Gale
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Significant recent developments.(most significant tax legislation): An article from: The Tax Adviser
This digital document is an article from The Tax Adviser, published by Thomson Gale on January 1, 2007. The length of the article is 4753 words. The page length shown above is based on a typical 300-word page. The article is delivered in HTML format and is available in your Amazon.com Digital Locker immediately after purchase. You can view it with any web browser.
Citation Details
Title: Significant recent developments.(most significant tax legislation)
Author: Don W. Bakke
Publication: The Tax Adviser (Magazine/Journal)
Date: January 1, 2007
Publisher: Thomson Gale
Volume: 28 Issue: 1 Page: 26(6)
Distributed by Thomson Gale
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