Economic ownership of shares assigned as collateral
In a most recent decision, the Supreme Tax Court held that the shares transferred by way of security are attributable to the purchaser ( who is also the secured party) as of the date of transfer of ownership if the purchaser can legally and effectively exercise the material rights associated with the shares (in particular the sale and exercise of voting rights) and regardless whether the security event occurs.
Kategorien: Supreme Tax Court cases
Schlagwörter: Collaterals / Sicherheiten, share transf ...