Αποτελέσματα Αναζήτησης
(A) Parent-subsidiary controlled group For purposes of subsection (a)(1), if a corporation (referred to in this paragraph as “parent corporation”) owns (within the meaning of subsections (d)(1) and (e)(4)), 50 percent or more of the total combined voting power of all classes of stock entitled to vote or 50 percent or more of the total value ...
3 ημέρες πριν · Read Code Section 1563 of the IRC—determining definitions and special rules for certain controlled coporations. Access the full-text code on Tax Notes.
§ 1.1563-1 Definition of controlled group of corporations and component members and related concepts. (a) Controlled group of corporations — (1) In general — (i) Types of controlled groups. For purposes of sections 1561 through 1563, the term controlled group of corporations means any group of corporations which is—
In determining whether the stock owned by an individual possesses the requisite percentage of the total combined voting power of all classes of stock entitled to vote of a corporation, see paragraph (a)(6) of § 1.1563-1. (iii) For purposes of section 1563, and §§ 1.1563-1 through 1.1563-4, a legally adopted child of an individual shall be ...
22 Δεκ 2006 · Section 1.1561 -1(c)(1) provides that, for purposes of sections 1561 and 1563, the term corporation includes an electing small business corporation and refers to §1.1563-1(b)(2)(ii)(c) for the treatment of such a corporation as an excluded member of a controlled group of corporations. S pecifically, §1.1563-1(b)(2)(ii)(c) provides
11 Απρ 2011 · Paragraph (a)(1)(ii) of the proposed regulation states that in determining whether a corporation is included in a controlled group of corporations, section 1563(b) shall not be taken into account. Section 1563(b) defines a component member, including an excluded member and an additional member.
Thought should always be given to assure that the areas A 1, A 2, A 3 and A 4 adequately reflect the strength of the lug. For lugs with an unusual shape or a sudden change in cross section a conservative equivalent lug should as assumed.
