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The article focuses on the tax implication of rolling over shares upon S corporation's acquisition in the U.S. It mentions after the merger the target S corporation is converted to a disregarded entity or an LLC taxed as a partnership, and the sale is a deemed asset sale for tax purposes, and the portion not sold is considered a rollover interest.

Indirect transfers refer to situations where when foreign entities own shares or assets in India, the shares of such foreign entities are transferred instead of a direct transfer of the underlying assets in India. There are innumerable permutations to such indirect transfers, many of which have been sought to be taxed by the Indian Government in the recent past. Beginning from the Vodafone case involving a tax demand of approximately USD 2.1 billion, which was followed by knee-jerk amendments to the Income Tax Act annually, to the recent Cairn case involving a tax demand of approximately USD 1.6 billion, the imposition of this tax has taken quite a few twists and turns. This article seeks to summarize and present a brief timeline of the issues related to indirect transfers, including the unintended issues that arose and those that continue to remain unresolved. These unresolved issues present potential concerns for future investments into India and for current foreign investors with investments in India. Further recognizing that unilateral measures by countries in taxing indirect transfers can result in incoherence and uncertainty, the United Nations, International Monetary Fund, Organization for Economic Co-operation and Development and World Bank Group have come out with a draft paper aimed at achieving international consensus on this issue. [ABSTRACT FROM AUTHOR]

The article discusses the capital gains tax implications of U.S.-based retailer Walmart's investments in Indian online electronic commerce company Flipkart. Particular focus is given on the capital gains made in the Flipkart share sale by a non-resident investor. According to Rakesh Nangia, managing partner at Nangia & Co. LLP, gains arising from the transfer of share to Walmart could be subject to tax in India because the substantial value of such shares are derived from the country.

The article reports that the competing versions and terms on how the estate and income taxes will be implemented under the administration of U.S. President Donald Trump, considering the proposed ban of stock discounting on the transfer of minority interest in the family business.

The article discusses various court cases in Great Britain as of January 2014. Various cases presented include the Buzzoni v. HMRC, which was regarding inheritance taxation of assets at death, HMRC v Lloyds TSB Equipment Leasing (No.1) Ltd, which was concerning the finance leasing of two ships and analyzes when is tax saving the sole objective under Great Britain tax legislation, and Aberdeen Asset Management plc v HMRC which was concerning tax liability in share transfers.

The authors look at New York State's stock-transfer tax, expressing opposition to a proposal from New York Governor Andrew Cuomo to end the tax. They call for an end to the current rebate of the tax and discuss its history, the state's need for revenue, and U.S. and European proposals for financial-transaction taxes.

This article offers pieces of advice on business taxation in the U.S. There are several considerations in an immediate public offering transaction under Section 351. It requires that the transferor have control of the transferee corporation immediately after the transfer. The sale of stock by the shareholders might disqualify the Section 351 transaction. In cases where the U.S. Internal Revenue Service disallowed a deduction for expenses paid to a shareholder or employee of a closely held corporation, a disallowed deduction may result. To avoid this problem, shareholders are required to have an agreement on reimbursement for the amount of the disallowed expense. In consolidated financials, the Lifo method in inventory evaluation is not required as a method of taxation management.

The article discusses business and political issues as of April 1, 1957 including the federal budget proposed by former United States President Dwight Eisenhower, the stock transfer tax, and the need for donations to the American Red Cross. The U.S. Congress is trying to find programs to cut from President Eisenhower's proposed $71.8 billion budget. Other topics mentioned include the reforms of the stock transfer tax, the House Ways and Means Committee, and reasons for Red Cross donations.

Reports on threat of the brokers to move away from New York as the city proposes to impose a stock-transfer tax on New York Stock Exchange transactions. Opposition to the plans of Mayor John O'Brien by the Booing Boobs; Alternative to keep the brokers' offices here, but move the trading floor and Clearing House to Jersey; Complaints of the Stock Exchange about the excessive taxes.

Presents an implicit comment by two fictitious characters Homer Graves and Elmer Durkin on the balance budget of the U.S. Views of Graves on taxation and responsibility of Democratic leadership; Argument pertaining to the reduction of sales tax bill; Impact of amusement tax on theatre; Opinion on the stock-transfer and inheritance taxes.

The article focuses on latest developments that took place in the U.S. stock market. It mentions that New York Stock Exchange (NYSE) has upped its stock transfer tax, imposed on all stock trades transferred in New York city by 25 percent. It informs that Pacific stock exchange is informing brokers about savings they can make for their customers by trading on regional exchanges. The Philippine Stock Exchange (PSE) reveals that it will execute 199 shares at prices equal to NYSE quotes.

The article reports on the renewed interest in Exchange Place, Jersey City, New Jersey following the decision of New York to increase its stock transfer tax 25 percent and adopt a bond-transfer tax.

• Temporary regulations were issued regarding the application of Secs. 387(a) and (b)to certain transactions described in Sec. 304. • The IRS and Treasury published new final regulations governing gain recognition agreements filed in connection with certain outbound stock transfers under Sec. 367(a). • A comprehensive package of proposed regulations outlines a uniform proposal for the allocation and recovery of basis in various transactions involving corporate stock or securities. • Temporary regulations and a notice were published regarding the anti-inversion provisions of Sec. 7874. • In May 2009, the White House and Treasury published a detailed explanation of the proposed budget, including a number of legislative proposals that would affect U.S.-based multinational corporations. [ABSTRACT FROM PUBLISHER]

The article focuses on the rules of the U.S. Internal Revenue Service (IRS) on determination basis for tax-free asset and stock acquisitions. It cites the requirements of Section 368 on type B reorganization or stock-for-stock and reverse triangular merger. Under Section 362(b), the buyer must use the same basis in determining the target stock in a type B reorganization as that of the target shareholders in their target stock. IRS has released the Revised Proclamation 81-70 and the Notice 2009-4 to provide guidelines for determining stock basis.

The article reports on the impact of the 50% increase in the stock-transfer tax proposed by Mayor John Lindsay in Wall Street, New York City in 1966. Brokers had protested that the tax was unfair to out-of-state investors who account for 70% of the 130 billion dollars annual business of the New York Stock Exchange. Big Board cancelled its plans to build a 80 million dollars headquarters in Manhattan and threatened to move lock, stock and trading booths outside the state.

The article reports that the New York Stock Exchange (NYSE) was close to being moved to Newark, New Jersey in March 1959 because of a proposed tax on stock transfers in New York City, with focus on the actions of NYSE president G. Keith Funston.

The article presents the editor's response to a letter regarding the U.S. federal stock transfer tax rate for the hotel company Loew's Inc.

A letter to the editor is presented in response to the article “The Power to Tax” in the April 1, 1957 issue.

The article looks at how mutual funds can stop net redemptions by swapping fund shares for private investment companies' shares, with special attention given to U.S. investment adviser Union Service Corp. Topics include taxes for capital gains, stock appreciation, and an exemption order issued by the U.S. Securities & ExchangeCommission (SEC). A chart regarding net redemption, net sales, and no-load funds figures as of 1972, is also presented

The article reports that the New York Stock Exchange (NYSE) has said that it is planning to move its trading post out of the state to evade the New York State transfer tax, which has been recently increased.

The author provides pieces of advice on taxation issues in the U.S. as of September 1938. He explains the taxation involves in transferring stocks to son, the exemption of an attorney's salary for Federal income-tax purposes and the sale of stocks to wife. He also discusses the selling of pledged stock.

The article offers information on price/earning (p/e) ratios. P/e ratios are high priced stocks that are assumed to be popular. It is believed that the more popular the stock, the more likely that it will increase. This belief reportedly gives basis for holders of popular stocks to sell at a higher price later. Head of First Boston Corp. research Robert M, Baylis believes that such popular stocks take a longer time to recoup investment compared to the average ones.

The article reveals that the Philadelphia-Baltimore-Washington Stock Exchange will be moving out of Philadelphia to avoid a controversial stock transfer tax. It involves a proposed school tax where the exchange will have to pay 5 U.S. cents on every share of traded stock in the city effective January 1, 1969. Stock brokers are also opposing the new tax, saying that it would have a negative effect on the financial community's competitiveness with New York and other areas in the U.S.

Discusses several developments on tax rulings, statutes and court decisions in the United States from July 1, 2000 to June 30, 2001. Enactment of a ruling on the impact of liabilities on the basis of tranferred stocks; Regulations on distributions of controlled corporation stock or securities; Decision regarding recognition on duplicated losses of subsidiary stocks.

The article discusses the implications of India's 2018 union budget in terms of the Insolvency and Bankruptcy Code (IBC) 2016. It states that the budget failed to resolve some of the issues faced by the Corporate Debtor (CD) under the IBC 2016 such as the tax transfers of shares of CD below its book value. It also mentions that budget proposes deduction of accumulated losses while computing book profits for companies under insolvency.

Discusses the US Internal Revenue Service's (IRS) Letter Ruling 9436005 attributing value for transfer tax purposes to the swing vote characteristics of stock transferred to family members. Assignment of value to gifts of stock; Minority interest discounts; History of swing vote attributes; Strengths and weaknesses of ruling.

The article discusses the tax demand on Scotland-based oil and gas exploration and production company Cairn Energy PLC for alleged capital gains it made in restructuring its business and share transfer in India eight years ago before 2015. Particular focus is given to the plan of the company to contest the order claiming that it has received a draft assessment order from the Income Tax Department of India in respect of the financial year from 2006 to 2007.