I therefore illustrate some paradigmatic circumstances for when and how personal jurisdiction protects plaintiffs in venue-transfer cases by restricting the range of transferee
The Court of Tax Appeals (CTA) en banc discussed the foregoing exception in a recent case (CTA EB 1713) where the Court emphasized the requisites of tax-free exchange, to wit: (a) the transferee
is a corporation; (b) the transferee
exchanges its shares of stock for property/ies of the transferor; (c) the transfer is made by a person, acting alone or together with others, not exceeding four persons; and, (d) as a result of the exchange the transferor, alone or together with others, not exceeding four, gains control of the transferee
2012-57; see "Tax Matters: Tax Court Respects Stock Sale, Denies Transferee
Liability," JofA, May 2012, tinyurl.com/y8qkfkm4).
According to the statement of facts stipulated to by the parties before sentencing, Pino "[o]n or about March 12, 2016, Defendant purchased for $439.99 a Glock, Model 23, .40 caliber semi-automatic pistol, bearing serial number ABKC629US, from the Marine Corps Exchange." In making this purchase, "Defendant completed an ATF Form 4473." On the ATF Form 4473, Defendant "checked the box indicating that he was the actual buyer and transferee
of the firearm even though he was really planning to resell the firearm for profit." "Later that day, the [D]efendant sold the Glock 23, which was in brand-new condition and packaged in the box with grip extensions."
Tribune Media Company ("Transferor") of Chicago, IL, has filed an application to sell the property to Sinclair Divestiture Trust ("Transferee
") of Stamford, CT.
The valuation made by the transferee
under and reasons that consideration is less than the fair market value shall be recorded in writing.
The government may also pursue transferees
of gifts or estate property for unpaid taxes of the decedent under the general transferee
liability provision contained in IRC section 6901.
from Cebu, Mbala had to wait for two seasons after his transfer to Manila from Southwestern University before he could play at the UAAP.
It highlights a media statement released by the Australian High Commission clarifying that the transferee
who sustained injuries had breached the external perimeter fencing of the centre.
Deductions do not transfer to the transferee
, and there is no adjustment to the disposal gain or loss reported for federal tax purposes.
(4) Did this addition of "actual fraud" mean that the transferee
of a fraudulent transfer was barred from discharging the transferee
's obligation to the transferor's creditor?