WebJun 2, 2014 · Granite Trust. GraniteTrust Co. v. U.S ., 238 F2d 670 (1st Cir. 1956) ruled that a parent’s sale of more than 20 percent of the stock of a subsidiary to an unrelated person was a proper set up ... Webthe U.S. tax system). Congress considered these types of loss importation transactions abusive on the grounds that it is inappropriate to allow a U.S. federal income tax deduction for an economic loss that arose outside of the U.S. tax system. 5. Accordingly, sections 362(e)(1) and 334(b)(1)(B) generally require the corporate transferee of built-in

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WebMs. Neto joined Granite REIT as Chief Financial Officer on July 8, 2024 and is responsible for the REIT’s financial planning, accounting & reporting, tax, treasury and corporate finance activities. Ms. Neto has over thirty years of varied business experience, including thirteen years as a CFO for publicly-traded real estate investment trusts ... WebApr 23, 2015 · – Control may be broken in contemplation of the liquidation transaction. Granite Trust Co., 238 F.2d 670 (1st Cir. 1956) – Pre-liquidation transfers of subsidiary … greenpeace polska facebook

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