Schlagwörter: downstream merger (3 gefunden)

1. 26. August 2016

   No trade tax loss carry-forward with merger of two-tier part ...

   In its decision of 12 May 2016 the Supreme Tax Court held that -in the case of a two-tier partnership structure- the trade tax loss carry-forward of the lower-tier partnership is fully eliminated, if the upper-tier partnership, which holds a 100% -interest in the income and assets of the lower-tier partnership, is merged down-stream and thus ceases to exist. Referring to previous case law, the Court’s reasoning was that the upper-tier partnership, as co-entrepreneur of the lower-tier partnership, was also the holder of the partnership’s trade tax loss-relief.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: downstream merger, trade tax, Two-Tier P ...
2. 21. März 2013

   Asset transfer costs from sidestream and downstream mergers ...

   The Supreme Tax Court has held that the exclusion of merger cost as part of the non-taxable profits and losses on merger also applies to indirect shareholdings.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: downstream merger, merger, sidestream me ...
3. 20. Januar 2011

   Upstream merger does not imperil loss carry forward of survi ...

   The Supreme Tax Court has held that a downstream, but not an upstream, merger leads to new assets for the surviving entity that can imperil its loss carry forward.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: loss carry forward, share acquisition, s ...