 | Joseph B. Darby - 2006 - 542 pages
...means stock possessing at least 80 percent of the total combined voting power of all classes of Target stock entitled to vote and at least 80 percent of...number of shares of all other classes of stock of the Target.34 The IRS interprets Code Sec. 368(a)(2)(E) as requiring that the Subsidiary must be a first-tier... | |
 | CCH Incorporated - 2007 - 872 pages
..."control" means the ownership of stock possessing at least 80 percent of the 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 (Code Sec. 368(c)).15 The 80-percent figures are changed to 50 percent in the case of nondivisive (D)... | |
 | CCH Tax Law Editors - 2008 - 1872 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...of all other classes of stock of the corporation. (2) All of the details in connection with an involuntary conversion of property at a gain (including... | |
 | CCH Tax Law Editors - 2008 - 2276 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) Non-stock organization. — In the case of a... | |
 | David F. Windish - 2007 - 700 pages
...after the transfer. Control, in this case, means 80 percent of the total combined voting power of all classes of stock entitled to vote and at least 80 percent of each class of nonvoting stock.41 Note that this tax-free transfer of money or property to a corporation... | |
 | Linda M. Johnson, CCH Tax Law Editors - 2008 - 746 pages
...transferors as a group own stock possessing at least 80 percent of the total combined voting power of all classes of stock entitled to vote and at least 80...number of shares of all other classes of stock of the corporation.2 Control must exist immediately after the exchange.3 "Immediately after the exchange"... | |
 | John C. Wisdom, James R. Hasselback - 2008 - 1350 pages
...own, immediately after the exchange, 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 outstanding shares of each class of nonvoting stock. (Code Sec. 368(c)) The term "property" does not... | |
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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... 
