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A non-simultaneous exchange is sometimes called a Starker Tax Deferred Exchange, named for an investor who won a case against the Internal Revenue Service (IRS). [ 3 ] For a non-simultaneous exchange, the taxpayer must use a Qualified Intermediary , follow guidelines of the IRS, and use the proceeds of the sale to buy qualifying, like-kind ...
A tax inversion or corporate tax inversion is a form of tax avoidance where a corporation restructures so that the current parent is replaced by a foreign parent, and the original parent company becomes a subsidiary of the foreign parent, thus moving its tax residence to the foreign country. Executives and operational headquarters can stay in ...
In business, consolidation or amalgamation is the merger and acquisition of many smaller companies into a few much larger ones. In the context of financial accounting, consolidation refers to the aggregation of financial statements of a group company as consolidated financial statements.
The 3-D printing industry is up and coming, and two companies -- 3D Systems and Stratasys -- are leading the way. Both are growing organically and via acquisitions, and their stocks have been ...
If the taxpayer wants to change a tax accounting method, section 446 of the Internal Revenue Code requires the taxpayer to obtain the consent of the Internal Revenue Service. There are two kinds of changes: obtaining a letter of approval from the IRS, and obtaining a series of more routine changes, each of which is an automatic change.
A disadvantage of this structure is the tax that many jurisdictions, particularly outside the United States, impose on transfers of the individual assets, whereas stock transactions can frequently be structured as like-kind exchanges or other arrangements that are tax-free or tax-neutral, both to the buyer and to the seller's shareholders.
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 ...
A company's earnings before interest, taxes, depreciation, and amortization (commonly abbreviated EBITDA, [1] pronounced / ˈ iː b ɪ t d ɑː,-b ə-, ˈ ɛ-/ [2]) is a measure of a company's profitability of the operating business only, thus before any effects of indebtedness, state-mandated payments, and costs required to maintain its asset base.