übertragende Körperschaft
English translation: transferring entity
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| 11:09 Dec 5, 2003 |
| German to English translations [PRO] Bus/Financial | |||||||
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|  Selected response from: Steffen Walter Germany Local time: 18:14 | ||||||
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| Summary of answers provided | ||||
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| 5 | transferring entity |
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| 3 +1 | transferring corporation [entity] |
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Answers
12 mins confidence: 
peer agreement (net): +1
peer agreement (net): +1transferring corporation [entity] Explanation: Extract from source #1: "Under the Directive, a corporation effecting the merger by inter-corporate transfer of assets is not granted the right to give the shares received in return for the assets and liabilities transferred a value for tax purposes equal to their fair market value (but may be required under domestic law to give them a value equal to the book value of the assets and liabilities transferred), thereby creating an opportunity for the government to tax the ***transferring corporation*** effectively for a gain that is already going to be taxed to the acquiring company upon its future disposition of the assets and liabilities." Extract from source #2: "In addition, if the stock were issued with a forfeiture provision, upon forfeiture the stock would revert to the ***transferring corporation***. The ***transferring corporation*** would have to recognize a gain or loss as if it had sold the stock for value. If the stock reverted to the issuing corporation, however, the transferor would receive nonrecognition treatment." -------------------------------------------------- Note added at 16 mins (2003-12-05 11:25:58 GMT) -------------------------------------------------- See also usage of \"transferring entity\" at: http://www.firstam.com/faf/html/cust/jm-entitychange.html -------------------------------------------------- Note added at 19 mins (2003-12-05 11:29:30 GMT) -------------------------------------------------- BTW, \"Gewerbeverlust\" should be \"trade loss\" or \"trading loss\". Reference: http://www.itpa.org/open/summaries/monte96s.html Reference: http://www.findarticles.com/cf_dls/m6280/4_187/54360134/p1/a... |
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2 hrs confidence:
transferring entity Explanation: Koerperschaft does not indicate the type fo entity involved, i.e. corporation, limited partnerschaft, etc. Therefore, the only correct answer is transferring entity. |
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