Corporations - Second circuit adopts "firm and fixed plan" test for purposes of integration of transactions
Article Abstract:
The Second Circuit court has upheld the ruling of the Tax Court in the Merrill Lynch & Company, Inc., 94 AFTR 2d 2004-6119 (CA-2, 2004), aff'g in part, remanding in part, 120 TC 12 (2003) case. The court observed that cross-chain sales by the subsidiary of Merrill Lynch did not result in dividend income to the subsidiary and did not increase Merrill Lynch's basis in the subsidiary. The court adopted the "firm and fixed plan" test to arrive at the ruling.
Publication Name: Business Entities
Subject: Business
ISSN: 1524-3583
Year: 2005
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Partnerships - District Court allows shifting of taxable income to foreign partners
Article Abstract:
The court has upheld the transaction of the General Electric Capital Corporation, which entered into a partnership with two Dutch banks to enable it to shift a significant portion of its taxable lease income from their fully depreciated aircraft to its partners. This was the ruling given by the court in the TIFD-III-E, Inc., 94 AFTR 2d 2004-6635 (D.Conn.2004) case.
Publication Name: Business Entities
Subject: Business
ISSN: 1524-3583
Year: 2005
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