The general venue-transfer statute contemplates transfer for all further proceedings, including trial and judgment, in the transferee
Unfortunately, for one of the parties in exchange in BIR Ruling 1113-2018, the BIR declined to grant exemption on the transfer of her parcel of land to a transferee
corporation because she obtained only 5.6 percent equity after the transfer, notwithstanding that together with the transfer of parcels of land and other improvements of the other transferors to the same transaction, their combined total voting equity is at 98.5 percent.
The Ninth Circuit, reversing the Tax Court and remanding with instructions to enter judgment in favor of the IRS, found that former shareholders of a liquidated broadcasting company were liable as transferees
However, based on the facts set forth in the statement of facts, Pino was, in fact, the owner and transferee
of the subject firearm, albeit for a brief period of time.
If the Directorate General is satisfied with the objections or reasons furnished by the transferee
or the transferor, it shall, by order in writing, declare that the property shall not be acquired under this section.
The issues raised above require due diligence to investigate the decedent's unpaid tax obligations, understanding of the correct amount of the estate tax liability and potential for additional assessment, informing beneficiaries of any special lien and transferee
liability exposure, and attempting to mitigate the executor's personal liability by requests for prompt assessment and discharged.
'Our position is that the latest rules as approved by the Board of Trustees in its meeting held on May 24, 2016, in Pico de Loro, Batangas, are very clear and specific with regard to the one-year residency requirement for transferees
from non-UAAP universities,' he said.
It involved asylum seekers, referred to as 'transferees
', held at an offshore processing centre.
The future North Carolina deductions taken by the transferee
are based upon the appropriate federal depreciation convention.
The McClellan court also addressed the question of whether a transferee
"obtains" assets "by" actual fraud: "The words 'obtained by' go with 'money, property, [or] services,' not with 'debt.' A debt is not something you obtain; it is something you incur as a consequence of having obtained [property]...." (21) The court concluded, therefore, that it was possible that the transferee
"obtained" the transferor's property "by" actual fraud if the transfer was fraudulent and the transferee
bore the requisite intent, thus incurring a nondischargeable debt to the transferor's creditors.
If the transferee
changes positions, however, he should remain aware of the time limits for L-1A and L-1B status, which are seven and five years, respectively.