 | 1987 - 50 pages
...exchange (sec. 351). Control is defined for this purpose as ownership of at least 80 percent of the stock entitled to vote and at least 80 percent of the total number of shares of all other classes of stock (sec. 368(c)). The control requirement for taxfree contributions by shareholders... | |
 | 1989 - 552 pages
...exempt organization of stock possessing at least 80 percent of the total combined voting power of all classes of stock entitled to vote and at least 80 percent of the total number of shares of all other classes of stock of such corporation. (b) Nonstock organization. In the case of a nonstock... | |
 | United States. Tax Court - 1989 - 1150 pages
...(c)) at least 80 percent of the total combined voting power of all classes of stock of a corporation entitled to vote, and at least 80 percent of the total number of shares of all other classes of stock of such corporation, and "(2) such corporation has been engaged in the... | |
 | Howard Abrams, Richard L. Doernberg - 1999 - 1044 pages
...which requires that the transferors own at least 80 percent of the total combined voting power of all classes of stock entitled to vote and at least 80 percent of the total number of shares of all other classes of stock. Like many provisions in the corporate tax area, the 80 percent requirement... | |
 | 2000 - 586 pages
...as the ownership of stock possessing at least 80 percent of the total combined voting power of all classes of stock entitled to vote and at least 80...shares of all other classes of stock of the corporation (sec. 368(c)). For purposes of determining whether two corporations are sufficiently affiliated so... | |
 | 2003 - 1082 pages
...means the ownership of stock possessing at least 80 percent of the total combined voting power of all classes of stock entitled to vote and at least 80 percent of the total number of shares of each other class of stock of the corporation (the "Control Requirement"). See lRC ยงยง 351(a), 368(c);... | |
 | Alexandra Reed Lajoux, H. Peter Nesvold - 2003 - 402 pages
...distributions); (2) the parent must possess at least 80 percent of the total combined voting power of all classes entitled to vote and at least 80 percent of the total number of shareholders of all other classes of stock (expect nonvoting stock, which is limited and preferred... | |
 | United States. Congress. Joint Committee on Taxation - 2005 - 450 pages
..."control" as ownership of stock possessing at least 80 percent of the total combined voting power of all classes of stock entitled to vote and at least 80...of all other classes of stock of the corporation. This section 355 definition of "control" is the definition generally used for purposes of the tax provisions... | |
 | Grant W. Newton, Robert Liquerman - 2005 - 768 pages
...in control must own stock processing at least 80 percent of the total combined voting power of all classes of stock entitled to vote and at least 80 percent of the total number of shares of each class of nonvoting stock of the corporation.205 (ii) Distribution of Control In addition to... | |
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... at least 80 percent of the total combined voting power of all classes of stock entitled to vote, and at least 80 percent of the total number of shares of all other classes of stock (except nonvoting stock which is limited and preferred as to dividends... 
