Subsidiary's Deemed Liquidation Is Income, 3rd Circ. Hears

Law360, Philadelphia (December 17, 2013, 7:28 PM EST) -- An attorney for shareholders of a Pennsylvania-based investment corporation told the Third Circuit on Tuesday that Internal Revenue Service rules allowing companies to claim the value of their subsidiaries’ assets made it possible for her clients to avoid taxes on some $230.1 million realized from a 2003 stock sale.

Schnader Harrison Segal & Lewis LLP attorney Nancy Winkelman urged a three-judge panel to reject a lower court’s ruling, which concluded that shareholders of Wind River Investment Corp. had improperly increased the stated value of their stock...
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