Submit Analysis And Gain Agreement

(x) A non-recognition transaction has the meaning defined in section 7701 (a) (45). In addition, a non-recognition transaction includes an exchange described in points 351 (b) or 356, even if all gains made on the stock exchange are recorded. (5) Certain distributions or transfers of shares or securities transferred to U.S. persons. To the extent that the distribution or transfer of the transferred shares or securities satisfies the conditions set out in paragraphs (o) (5) to (iii) of this Section, the earnings recognition agreement shall terminate without further effect or the amount of profits subject to the profit recognition agreement shall, where appropriate, be reduced. (4) Disposals of all the assets of a transferred national company. Except as otherwise provided in this paragraph (o) (4), the profit adjustment agreement shall terminate without further effect if, for the most part, all the assets of the transferred company are sold in a transaction in which all the profit realized is recognised and included in taxable income in the tax year of the transfer, but only if, at the time of the first assignment, the American contemptuous held shares of the transferred company, which met the requirements of Section 1504(a)(2), and the American contemptuous and the transferred company were members of the same consolidated group. If the initial transfer was part of an indirect transfer of shares, the profit-making agreement terminates without further effect if, for the most part, all the assets of the transferred entity (taking into account Article 1.367(a)-3(d)(2)(v)) are sold in a transaction which included all the profit made in the tax year of the transfer and is included in taxable income; but only if, at the time of the first assignment, the U.S. contemptuous possessed shares of the transferred company that met the requirements of Section 1504(a)(2)(z.B. in the case of a reorganization described in Section 368(a)(1)(A) on the basis of Section 368(a)(2)(E)) and the Contemptuous U.S. and the transferred company were members of the same consolidated group.

(C) Where applicable, a calculation of the amount of profit which, by reason of the application of paragraphs (m), n) or (o) of this Section, is subject to the new agreement on the recognition of profits. (1) The transfer of stocks of TFC by UST to FA is described in Article 361(a) and is therefore subject to Article 367a(5). As a general rule, UST cannot submit a recognition of profits agreement with respect to such a transfer and therefore the transfer is subject to the general rule of Section 367(a)(1). However, if the conditions set out in paragraphs 1.367(a) to 3(e) (1) (i) to (iv) are met, USP may enter into a profit recognition agreement with respect to the transfer in order to prevent the UST from recording the profit at the time of the transfer under Section 367(a)(1). whether the exemption under subsection (k) (14) of this Section applies in such a way that the transfer of TFC shares by UST to FA does not constitute a triggering event with respect to the profit realization agreement submitted for the initial transfer [discussed in paragraph (q) (2) (vi) (B) (2) of this Section (subsection (2) in the results of Example 6); The amount of profits subject to the profit realization agreement (if concluded) with respect to the transfer of TFC shares by UST to FA as part of the wealth reorganization is 100 times higher. (1) Successive transfers in accordance with Section 351. In accordance with the provisions of Section 367(a)(4) and Section 1.367(a)-1T(c)(3)(ii), the transfer of the PRS interest by UST to TFC for the purposes of Section 367(a) shall be treated as a transfer by UST of its share in respect of the TFD shares held by PRS to TFC (initial assignment). . .

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