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22-Jul-2018 08:57

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shareholder could be subject to branch profits tax on liquidating distributions.Although liquidating distributions to domestic shareholders are generally treated as a sale of stock and are exempt from FIRPTA taxation, as discussed above, the same distributions to non-U.It is rumored that Chantal was initially chosen to be the Bachelorette but she backed out after meeting her new boyfriend.Toward the start of his recap of Ashley’s first night as the Bachelorette, Steve wrote, “Lets face it, if Chantal didn’t meet Jeff Razore right after her filming, Ashley wouldn’t even be in this position.shareholder “would be treated as gain on the sale of U.

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I’ll take full credit for being the first one to expose their relationship publicly.”If it’s true, that was quick work on Chantal’s part!The Senate Report explained that the 5% Exception was meant to remove “from treatment as effectively connected income for a foreign investor a capital gain distribution from a REIT” and justified it as a means to “provide greater conformity in the tax consequences of REIT distributions and other corporate stock distributions.” The use of the language “capital gain distribution from a REIT” would suggest that the Senate Report was referring to capital gains dividends, rather than liquidating distributions and that the distributions to which the 5% Exception (and, thus, Code Sec.857(b)(3)(F), enacted at the same time as the 5% Exception, which recasts distributions subject to the 5% Exception as ordinary dividends, applies only to the amount which would be considered capital gain dividends (and not liquidating distributions).This disparity in treatment would suggest again that Congress did not intend Code Sec.



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