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A Reverse Morris Trust is used when a parent company has a subsidiary (sub-company) that it wants to sell in a tax-efficient manner. The parent company completes a spin-off of a subsidiary to the parent company's shareholders. Under Internal Revenue Code section 355, this could be tax-free if certain criteria are met. The former subsidiary (now ...
Strictly speaking, the Grantor of a trust is merely the person creating the trust, [12] usually by executing a trust agreement which details the terms and conditions of the trust. Such a trust can be revocable or irrevocable. A revocable trust is one in which the settlor retains the ability to alter, change or even revoke the trust at any time ...
合同会社 (gōdō gaisha or gōdō kaisha, "G.K.") – lit. "amalgamated company", a close corporation form similar to the American LLC, introduced in 2006 有限会社 (yūgen gaisha or yūgen kaisha, "Y.K.") – lit. "limited company", a close corporation form for smaller businesses, abolished in 2006 and replaced by G.K. above
Form 10-12B is a U.S. SEC filing used to register securities pursuant to Section 12(b) of the Securities Exchange Act of 1934 in the United States. [ 1 ] Form uses
The US holding company receives a loan from its home country parent which it invests in a US operating subsidiary; the US holding company receives dividends from the US operation subsidiary and pays interest to the non-US parent. US tax law thus sees a US company making a dividend payment to another US company (which is thus not subject to ...
It does not capture the decisions of a single enterprise, or a single economic entity, even though the form of an entity may be two or more separate legal persons or companies. In Copperweld Corp. v. Independence Tube Corp. [ 38 ] it was held an agreement between a parent company and a wholly owned subsidiary could not be subject to antitrust ...
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Irrevocable trust: In contrast to a revocable trust, an irrevocable trust is one in which the terms of the trust cannot be amended or revised until the terms or purposes of the trust have been completed. Although in rare cases, a court may change the terms of the trust due to unexpected changes in circumstances that make the trust uneconomical ...