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In a mutual-holding-company conversion, the original mutual insurer becomes a stock insurance company that is wholly owned by a mutual holding company.
10) Subpart J governs the conduct of merchant banking investment activities by financial holding companies as permitted under section 4(k)(4)(H) of the Bank Holding Company Act (12 U.
Under this strategy, if Target pays interest expenses to Holding that matches or almost matches the interest expense paid by Holding to third parties, the operating income of Target should be effectively sheltered.
I must confess, there was a bit of romance involved in that situation, but having a woman already holding a crumpled tissue decide we should hold it together to pray is something else.
Language was inserted in the early versions of the correcting legislation expanding the IRA-related provisions to depository holding companies by amending Secs.
86--What activities are permissible for financial holding companies?
Huddleston, the Supreme Court of Tennessee, in holding that gains from the sale of shopping centers were nonbusiness income, said that the taxpayer was not in the business of selling real estate, noting that its principal business activity was to own and lease shopping centers to retailers, including its corporate parent.
After the long-term holding period is met and development is ready to begin, the partnership sells the property to a second entity set up as a commonly owned S corporation.
In addition, the Federal Financial Institutions Examination Council will be discussing bank capital requirements on equity investments, a discussion that will, of course, be considered in the Board's final decision on holding company capital requirements on these assets.
However, it added a caveat to the requested ruling: "[N]o inference should be drawn from this letter that any gain from the sale of [H&C's] assets immediately following its election to be disregarded as an entity separate from its owner gives rise to gain that is not foreign personal holding company income as defined in section 954(c) (1)(B).
13 & 14 - BAM Local Development Corporation and Long Island University is holding a free, two-day seminar entitled "Real Estate and the Arts: Translating Your Vision Into Space (You Can Afford.