1. The condition set out in point (k) (14) (i) of this section is met, as the allocation of TFD stock and the exchange of F1 shares are considered non-recognition operations. (i) In the case of a stock exchange to which the assets of a foreign acquisition company receiving shares in a foreign acquisition company apply, the U.S. divester includes, in the new Earnings Recognition Agreement, a declaration that a full or partial sale of the foreign purchaser received on the stock exchange is a triggering event. The principles of paragraph o) (1) or (ii) apply, if applicable, to determine whether a subsequent sale, total or partial, of the stock of shares of the foreign acquisition company received on the stock exchange terminates or reduces the amount of the new profit recognition agreement. With exceptions, Section 367(a) (1) requires a U.S. person (U.S. ceding) who transfers assets, including shares or securities, to a foreign capital company in connection with a stock exchange described in sections 332, 351, 354, 356 or 361 (non-recognition transaction) to detect profits. Section 1.367 (a)-3 provides a departure from the general recognition rule under Section 367 (a) (1) for certain outbound transfers of shares or securities where the U.S. assignor has an GRA pursuant to Reg`s provisions. 1.367 (a)-8 (GRA regulations) and presents some other related documents. (B) Result.
In accordance with paragraph m (1) of this section, UST must recognize a profit of 35 X as part of the Benefit Recognition Agreement following the sale of the TFD share by TFC in 3. Therefore, the amount of profit subject to UST`s new profit recognition agreement pursuant to paragraph (3) of this section is 15x. In accordance with paragraph (c) (4) (ii) of this section, at the time of the first transmission, the basis of the TFD stock held by TFC is multiplied by 35 times, the amount of profit recognized by the UST under the benefit recognition agreement. In accordance with paragraph (c) (4) (i) of this section, the base of the TFC stock received during the initial transfer is also increased by 35 X. After taking into account the increase in the stock of TFD referred to in paragraph c) (4) (ii) of this section, the TFC recognizes 15 x us-gewinn according to section 351 (b) with respect to the transfer of the TFD stock to F1. In accordance with Section 362 (a), the base of the TFD stock is in the hands of F1 100x. (g) Annual Certification. Unless provided for in paragraph (d) (i) (i) of this section, the U.S.
assignor must, for each of the five full taxable years following the fiscal year of the first assignment, provide a certificate (annual certificate) in a timely manner, containing, if applicable, the information described in paragraphs (g) (1) to (3) of this section. The annual certificate is signed by a person authorized, in accordance with paragraph e) (1) of this section, to sign the recognition agreement for the first transmission. The registration of an unsigned copy of the annual certificate, accompanied by the return of the U.S. cedant in a timely manner, must meet the signature requirement in paragraph (e) (1) of this section, provided that the U.S. ceded party retains the original signed certification in the manner referred to in paragraph 1.6001-1. (i) the amount of profit that depends on the recognition agreement at the time of recognition of benefits; (ii) a special scheme for the inclusion of benefits.