» Site Navigation |
|
|
|
» Online Users: 2,919 |
| 0 members and 2,919 guests |
| No Members online |
| Most users ever online was 9,654, 05-18-2025 at 05:16 AM. |
|
 |
|
06-16-2005, 07:53 PM
|
#46
|
|
Moderator
Join Date: Mar 2003
Location: i put on my robe and wizard hat
Posts: 4,838
|
Holy crap
Quote:
Originally posted by Nut Case, Sensitive
I couldn't agree more. Do you mind having a squirrel around?
I may eat your nuts and chatter too much, but I can be kind of amusing.
|
I am become death, the destroyer of worlds.
__________________
I'm going to become rich and famous after I invent a device that allows you to stab people in the face over the internet.
|
|
|
|
06-16-2005, 08:06 PM
|
#47
|
|
I am beyond a rank!
Join Date: Mar 2003
Location: Glasgow, natch.
Posts: 2,807
|
Holy crap
Quote:
Originally posted by Flinty_McFlint
I am become death, the destroyer of worlds.
|
All your base are belong to us. |
|
|
|
|
06-16-2005, 09:07 PM
|
#48
|
|
Moderator
Join Date: Mar 2003
Location: i put on my robe and wizard hat
Posts: 4,838
|
Holy crap
Quote:
Originally posted by str8outavannuys
All your base are belong to us.
|
934-Texas
__________________
I'm going to become rich and famous after I invent a device that allows you to stab people in the face over the internet.
|
|
|
|
|
06-19-2005, 11:34 PM
|
#49
|
|
Who's your rice daddy?
Join Date: Jun 2003
Posts: 33
|
355 Ruling Anyone?
Hello everyone. Long time, no post!
Well, I am filing my first PLR request under 355. Because they have become increasingly rare since the issuance of Rev. Proc. 2003-48, no one in my firm has filed one of these recently. Nor am I able to find any previous 355 ruling requests on our firm database. Vexing! I have a general sense of the format and the arguments that need to be made, but because of the strict requirements of Rev. Proc. 96-30, I would really like to see someone else's actual request under 355 before submitting this! Can anyone help me out?
Our transaction is a pure 355 spin-off of a 100% sub, pro rata to all shareholders. Not a split-off. Not a D reorg. Predictably, the issue here is the sub's active t/b. But I really don't need to discuss the substantive issues here. Just would like to see an example of what someone else has done in the past. Many thanks!
(No, we are not requesting a pre-submission conference. Long story.)
|
|
|
|
|
06-20-2005, 03:28 AM
|
#50
|
|
I am beyond a rank!
Join Date: Mar 2003
Location: Glasgow, natch.
Posts: 2,807
|
Holy crap
Quote:
Originally posted by Flinty_McFlint
934-Texas
|
Damn you! You win! 934-Texas trumps all.
I might have to head down to pipe storage and exact my revenge in Flinty-blood. |
|
|
|
|
06-20-2005, 10:37 PM
|
#51
|
|
Moderator
Join Date: Mar 2003
Location: i put on my robe and wizard hat
Posts: 4,838
|
Holy crap
Quote:
Originally posted by str8outavannuys
Damn you! You win! 934-Texas trumps all.
I might have to head down to pipe storage and exact my revenge in Flinty-blood.
|
Not so fast. Tax Hottie has a pretty good comeback with that 355 ruling post. That's pretty hot.
__________________
I'm going to become rich and famous after I invent a device that allows you to stab people in the face over the internet.
|
|
|
|
|
06-20-2005, 10:58 PM
|
#52
|
|
No title
Join Date: Apr 2003
Location: Here
Posts: 8,092
|
Holy crap
Quote:
Originally posted by Flinty_McFlint
Not so fast. Tax Hottie has a pretty good comeback with that 355 ruling post. That's pretty hot.
|
I guess the better question is why ask here on your island?
And why was everyone so bitchy today? I may have to spend the rest of the week here. |
|
|
|
|
06-21-2005, 02:36 PM
|
#53
|
|
Wild Rumpus Facilitator
Join Date: Mar 2003
Location: In a teeny, tiny, little office
Posts: 14,167
|
355 Ruling Anyone?
Quote:
Originally posted by tax_hottie
Hello everyone. Long time, no post!
Well, I am filing my first PLR request under 355. Because they have become increasingly rare since the issuance of Rev. Proc. 2003-48, no one in my firm has filed one of these recently. Nor am I able to find any previous 355 ruling requests on our firm database. Vexing! I have a general sense of the format and the arguments that need to be made, but because of the strict requirements of Rev. Proc. 96-30, I would really like to see someone else's actual request under 355 before submitting this! Can anyone help me out?
Our transaction is a pure 355 spin-off of a 100% sub, pro rata to all shareholders. Not a split-off. Not a D reorg. Predictably, the issue here is the sub's active t/b. But I really don't need to discuss the substantive issues here. Just would like to see an example of what someone else has done in the past. Many thanks!
(No, we are not requesting a pre-submission conference. Long story.)
|
Welcome back sweetness. Oh, and uh, this board isn't really all that substantive any more.
ETA sorry, TH, I only have an additional submission letter, not the original ruling request. I have a form ruling request, but it dates back to 1992, so I doubt it will be much help.
__________________
Send in the evil clowns.
Last edited by taxwonk; 06-21-2005 at 02:48 PM..
|
|
|
|
|
06-24-2005, 11:42 AM
|
#54
|
|
Wild Rumpus Facilitator
Join Date: Mar 2003
Location: In a teeny, tiny, little office
Posts: 14,167
|
Tax Fashion Statement
__________________
Send in the evil clowns.
|
|
|
|
|
06-24-2005, 11:51 AM
|
#55
|
|
Moderator
Join Date: Mar 2003
Location: Rose City 'til I Die
Posts: 3,309
|
355 Ruling Anyone?
Quote:
Originally posted by tax_hottie
Hello everyone. Long time, no post!
Well, I am filing my first PLR request under 355. Because they have become increasingly rare since the issuance of Rev. Proc. 2003-48, no one in my firm has filed one of these recently. Nor am I able to find any previous 355 ruling requests on our firm database. Vexing! I have a general sense of the format and the arguments that need to be made, but because of the strict requirements of Rev. Proc. 96-30, I would really like to see someone else's actual request under 355 before submitting this! Can anyone help me out?
Our transaction is a pure 355 spin-off of a 100% sub, pro rata to all shareholders. Not a split-off. Not a D reorg. Predictably, the issue here is the sub's active t/b. But I really don't need to discuss the substantive issues here. Just would like to see an example of what someone else has done in the past. Many thanks!
(No, we are not requesting a pre-submission conference. Long story.)
|
The FB has been woefully lacking in talk of curry-scented balls of late.
__________________
Drinking gin from a jam jar.
|
|
|
|
|
06-27-2005, 06:16 PM
|
#56
|
|
Random Syndicate (admin)
Join Date: Mar 2003
Location: Romantically enfranchised
Posts: 14,282
|
A whiff free zone.
Sanctuary!
__________________
"In the olden days before the internet, you'd take this sort of person for a ride out into the woods and shoot them, as Darwin intended, before he could spawn."--Will the Vampire People Leave the Lobby? pg 79
|
|
|
|
|
06-27-2005, 06:18 PM
|
#57
|
|
Registered User
Join Date: Mar 2003
Location: Flyover land
Posts: 19,042
|
Quote:
Originally posted by Replaced_Texan
Sanctuary!
|
In all seriousness, I think you are whiffing here. |
|
|
|
|
06-27-2005, 06:19 PM
|
#58
|
|
Moderator
Join Date: Mar 2003
Location: i put on my robe and wizard hat
Posts: 4,838
|
Quote:
Originally posted by ltl/fb
In all seriousness, I think you are whiffing here.
|
FINALLY! The wimmins have arrived! Party time! Naked lacrosse at 3!
__________________
I'm going to become rich and famous after I invent a device that allows you to stab people in the face over the internet.
|
|
|
|
|
06-27-2005, 06:23 PM
|
#59
|
|
Random Syndicate (admin)
Join Date: Mar 2003
Location: Romantically enfranchised
Posts: 14,282
|
Quote:
Originally posted by ltl/fb
In all seriousness, I think you are whiffing here.
|
Probably, but with less irritation. Especially now that I'm nekkid.
__________________
"In the olden days before the internet, you'd take this sort of person for a ride out into the woods and shoot them, as Darwin intended, before he could spawn."--Will the Vampire People Leave the Lobby? pg 79
|
|
|
|
|
06-27-2005, 06:24 PM
|
#60
|
|
Registered User
Join Date: Mar 2003
Location: Flyover land
Posts: 19,042
|
Quote:
Originally posted by Replaced_Texan
Probably, but with less irritation. Especially now that I'm nekkid.
|
I am neither naked nor equipped for lacrosse. Can't we just have an orgy instead? |
|
|
|
|
|
Posting Rules
|
You may not post new threads
You may not post replies
You may not post attachments
You may not edit your posts
HTML code is Off
|
|
|
|
Linear Mode
