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D. 9397 relates to the assumption of liabilities under Section 358(h). Section 358(h) provides that, after application of Section 358(d), the basis in stock received in a nonrecognition transaction shall be reduced to the fair market value of the stock by the amount of any liability assumed in the exchange.
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In the Merlo v. Commr. case, the petitioner exercised incentive stock options on December 21, 2000, acquiring 46,125 shares of E stock. As a result, the petitioner was required to include $1,066,064, the spread between the exercise price and the fair market value of the shares of E stock on the date of exercise, in his alternative minimum taxable income in 2000. Instead, the petitioner included only $452,025, the spread between the exercise price and the fair market value of the shares of E stock on April 15, 2001. The Tax Court held that the capital loss limitations of Sections 1211 and 1212 apply for purposes of calculating the alternative minimum taxable income. The petitioner's capital losses realized in 2001 do not create an ATNOL that can be carried back to reduce his alternative ...
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Business Editors
NASHVILLE, Tenn.--(BUSINESS WIRE)--July 9, 2001
Corrections Corporation of America (NYSE:CXW) announced today that it has determi...
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Business Editors
NASHVILLE, Tenn.--(BUSINESS WIRE)--Oct. 9, 2001
Corrections Corporation of America (NYSE:CXW) announced today that it has determi...
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Business Editors
NASHVILLE, Tenn.--(BUSINESS WIRE)--April 17, 2001
Corrections Corporation of America (NYSE:CXW) announced today that it has deter...
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... of 5 percent or more of the voting power or value of the stock of the grantor corporation (or a rela... salary at a price equal to 85 percent of the fair market value at the time the option is granted wil...
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My buy-sell agreement says I get bought out at the fair market value of my stock. Why does my partner say that means 60 percent of what my stock is really worth?
Many buy-sell agreements provide for a buyout at "fair market value." In other words, upon a triggering event such as death, disability, retirement, divorce or bankruptcy, the remaining business partner(s) will buy out the departing partner for a price equal to the "fair market value" of his or her interest in the business.
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Business Editors
NASHVILLE, Tenn.--(BUSINESS WIRE)--July 16, 2003
Corrections Corporation of America (NYSE:CXW) announced today it has determined ...
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...Moreover, if U.S. shareholders sold stock in the foreign corporation to raise cash in the Un... electing fund regime, and the mark-to-market regime. In addition to the substantive rules, ther... test"), or (2) at least 50% of the average fair market value of its assets during the year are ass...
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Business Editors
NASHVILLE, Tenn.--(BUSINESS WIRE)--Oct. 13, 2003
Corrections Corporation of America (NYSE: CXW) announced today that it has deter...