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R Ball for R Ball III by Appt, et al v. Commissioner of IRS
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February 12, 2014
3rd Circ. Closes Qualified Subsidiary Tax Election Loophole
The Third Circuit on Wednesday rejected a Pennsylvania-based investment corporation's attempt to avoid taxes on more than $230 million realized from a 2003 stock sale, saying the company violated Internal Revenue Service rules allowing companies to claim the value of their subsidiaries' assets.
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December 17, 2013
Subsidiary's Deemed Liquidation Is Income, 3rd Circ. Hears
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.