Acquisitions and Mergers in a Changing Environment, Issue 699Practising Law Institute, 1990 - Consolidation and merger of corporations |
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Page 142
... deferred tax liability is applied to only Bigco's separate $ 5 million installment gain or rather is applied to the Bigco group's aggregate $ 18 million deferred gain . This technique also apparently allowed the selling member to avoid ...
... deferred tax liability is applied to only Bigco's separate $ 5 million installment gain or rather is applied to the Bigco group's aggregate $ 18 million deferred gain . This technique also apparently allowed the selling member to avoid ...
Page 194
... Deferred Intercompany Gain The consolidated return regulations defer gain on certain transactions between group members , including the sale or distribution of property from one group member to another . See Reg . $ 1.1502-13 ( c ) ...
... Deferred Intercompany Gain The consolidated return regulations defer gain on certain transactions between group members , including the sale or distribution of property from one group member to another . See Reg . $ 1.1502-13 ( c ) ...
Page 227
... deferred com- pensation owed to its employees until the deferred com- pensation " is includible in the gross income of [ the ] employees . " This may mean that neither P nor T is allowed to deduct such deferred compensation liabilities ...
... deferred com- pensation owed to its employees until the deferred com- pensation " is includible in the gross income of [ the ] employees . " This may mean that neither P nor T is allowed to deduct such deferred compensation liabilities ...
Contents
CONTENTS | 7 |
Accounting Aspects of Acquisitions and Mergers | 27 |
Recent Accounting Developments and Trends in | 35 |
Copyright | |
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Common terms and phrases
338 election acquires T's assets acquires T's stock affiliated group aggregate allocation amended amount apply boot built-in gain capital gain carryback carryover basis cash Commissioner common stock consolidated return continuity corporation debentures debt instrument deduction deferred discussed distribution dividend entity equity escrow ESOP excess exchange golden parachute greenmail GU Repeal holder installment method investment issued issuer Leveraged Buyouts liability liquidation Mgmt million Newco stock notes old shareholders option ordinary income ownership change P-SCO parachute payment partnership period poison pill preferred stock prior private letter ruling purchase of T's purchase price purchases T's stock pursuant qualify recognize gain redemption regulations reorganization Reverse Subsidiary Merger rules securities sell shareholders receive shares SRLY stock purchase substantially T-SCO T's business T's NOL T's shareholders tax-free taxpayer Temp tender offer tion transfer transferor treated treatment voting stock