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When a person joins an existing partnership P by contributing assets this is equivalent to the formation of a P and is not reportable. Withdrawal from a P by having the P acquire the interest is not...
Called (redacted) 1-30-92. The first and second steps are exempt under c-3 and c-10. The last step (3rd) is reportable for both shareholders for the conversion. JS & RS concur.
12/26/91- called (redacted). Advised that Scenario A is reportable. (Do not trace partnership interest held thru to assets of partnership.) B is not reportable. C isreportable if, after redemption of...
12/19/91 (Redacted) advises that the (redacted) are built by a German firm. (Redacted) purchases them and arranges leases with persons needing equipment. Lessee uses this approach rather than...
12/18/91 advised (redacted) that contents of this letter did not reflect the presentview of the PMN Office. If land had produced a stream of income (which itapparently had) and size tests were met...
12/9/91 called (redacted). Advised that Tom and I were of the view that even though the Medical Group, the Hospital Corporation and the (redacted) had the same equity and interest holders, no one...
12/3/91 called (redacted) and advised that where a state Commissioner of Insurance, an elected state official, becomes the receiver or conservator of aninsurance company pursuant to a state statute...
Section 802.50(a)(2) requires a person to as certain the amount of sales in or in to the U.S. attributable to the foreign assets. A person may rely on financial records even though they are not...
Title (and other indicia of beneficial ownership) will remain w/ trust. Only cash equivalent (right to receive income stream) is being purchased. Payment for such is excluded from size-of-transaction...