lodas
6 hours ago
World stock market futures are tumbling as a result of todays announcement of tariffs on developing nations economies.....This announcement could signal the end of the "Great Bargain" america shared with the rest of the world after WW11...the Bretten Woods agreement allowed the American Dollar to be the Reserve Currency for the world, and allowed the U.S. to print money to subsidize the rebuilding of Europe, and the rest of the countries that were decimated in the Second World War... what was the "GRAND BARGAIN"?....in return for reduced export tariffs, these countries would BUY OR DEBT!!....America printed , and sold trillions of dollars of debt to every country in the world... they brought in exports cheap, we got cheap money to finance our debt.... through the years america went to the moon, built infrastructure, built the middle class, built the best armies and navies in the world, health care, institutions, and created the greatest number of Billionaires in the last 80 years. Now, when the Treasury has to roll the Debt, it will be interesting if these countries will buy it...if they dont, this country goes into default, or the interest rate on the new debt instruments WILL SOAR!!!!!!....IMO, this administration just pit the nail in the coffin of this once great country, and with the inability to print money, or lose the Dollar as the reserve currency. then the Great American experience is over....tomorrow, the stock market will sell off big time.... dont be fooled to rush in and buy... there will be intermittant ralleys, but unless, this administration lifts the tariffs, and makes friends with the rest of the world, a Depression will unfold.... Reason?.... the Fed is Broke, America is in debt for 36 trillion, interest rates will rise, and the middle class will be wiped out....."when you dont learn from your mistakes, you are bound to repeat them".... in 1929, congress enacted the Smoot-Hawley tariff act, just like today... and the worldwide depression started....watch your wealth.... as for Coop, and Rocket merger, MM will try to weasel you out of your stock....watch Warren Buffet... he will signal when to go back in..... good luck ...... Lodas
Large Green
11 hours ago
JHD51, yes, I know, but think of it this way. I was trying to relate that the PROCESS has publicly started. Yes, it could be Chase or anybody, but the process is what I wanted to relate, eventually ending with DST Safe Harbor Beneficial Distributions and/or a Private Placement of securities to those investors who have signed timely releases by March of year 2012.
...
newflow
12 hours ago
"BOOT" 61 Months - IMO, i think they are merging WAMU 1031 DE entity formed in 2017, 5 years exactly after closing the chapter 11 cases.
https://www.investopedia.com/terms/b/boot.asp
From the PLR LG referred those transaction are tax free.
The Internal Transactions
1. The Contribution, together with the Internal Distribution, will qualify as a
reorganization and distribution within the meaning of section 368(a)(1)(D) and
section 355. Internal Distributing and Controlled will each be “a party to a
reorganization” within the meaning of section 368(b).
2. No gain or loss will be recognized by Internal Distributing on the Contribution.
Sections 361(a), 361(b), and 357(a).
3. No gain or loss will be recognized by Controlled on the Contribution. Section
1032(a).
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The External Transactions
11.No gain or loss will be recognized by (and no amount will otherwise be included in
the income of) the External Distributing shareholders upon receipt of Controlled
stock in the External Distribution. Section 355(a)(1).
12.No gain or loss will be recognized by External Distributing on the distribution of
Controlled stock to its shareholders in the External Distribution. Section 355(c)(1).
13.Each participating shareholder’s aggregate basis in the Controlled stock it receives
in exchange for External Distributing stock pursuant to the Split-Off (including any
fractional share interest in Controlled stock to which a shareholder may be entitled)
will equal such shareholder’s aggregate basis in the External Distributing stock
surrendered in the Split-Off and will be allocated among the shares received in the
manner described in Treas. Reg. § 1.358-2(a). Section 358(a)(1) and (b)(1).
--------------------------------------------------------
17.Following the External Distribution, Controlled will not be a successor of External
Distributing for purposes of section 1504(a)(3). Therefore, Controlled and its direct
and indirect subsidiaries that are “includible corporations” under section 1504(b) and
satisfy the ownership requirements of section 1504(a)(2) will be members of an
affiliated group of corporations entitled to join in the filing of a consolidated U.S.
federal income tax return.
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3)5 years must elapse before reconsolidation
https://www.law.cornell.edu/uscode/text/26/1504
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https://www.taxnotes.com/research/federal/usc26/1504