B IBillroth Type I
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R]] for B is lower than or equal to the payoff, [delta](1 - S'), from getting the proposal, [S.
Unfortunately for S and I, B is no longer willing to make an offer above [delta]S', an amount that corresponds exactly to the continuation payoff for player S.
1502-14(d), gain or loss recognized by S in connection with a disposition of an obligation of B is generally taken into account as follows: (1) if the obligation is transferred outside the group or the member owning the obligation (if other than the member having the deferred gain or loss) leaves the group, such gain or loss is restored over the remaining term of the obligation; and (2) any remaining deferred gain or loss is taken into account on the earliest of the date on which (a) either S or B leaves the group, (b) the obligation is redeemed or canceled or (c) the stock of B is deemed disposed of under Regs.
Under the proposed regulations, B is treated as satisfying its note for $125 immediately before S's bad debt deduction and reissuing a new note with a $125 issue price and a $200 stated redemption price at maturity.
An intercompany obligation may also become a nonintercompany obligation and be subject to the special rules if the creditor or the debtor is deconsolidated (if, for example, after S acquires B's note, 25% of the stock of S or B is sold to a nonmember).
B is also treated as issuing a new note, with an issue price of $150 and a $200 stated redemption price at maturity, to S immediately after S becomes a nonmember.
The facts are the same as in Example 10, except that the stock of B is sold to X rather than S selling B's note.
1502-13(g)(4), B is treated as satisfying its obligation for $150 immediately after X becomes a member.
267(f)-1(a)(3) provides that S's sale to B is subject to both Prop.
For example, S's intercompany loss from a sale of property to B is treated as a noncapital, nondeductible amount if B distributes such property to an unrelated shareholder at no further gain or loss.
B is not a dealer and holds the security for investment.
1502-13(d)(1)(ii)(A) provides that B is treated as if it resold the equipment to a nonmember affiliate.