Not exact matches
But these deals, called
tax - equity deals, are relatively expensive to
structure and only a small number of companies appear
interested.
Such risks, uncertainties and other factors include, without limitation: (1) the effect of economic conditions in the industries and markets in which United Technologies and Rockwell Collins operate in the U.S. and globally and any changes therein, including financial market conditions, fluctuations in commodity prices,
interest rates and foreign currency exchange rates, levels of end market demand in construction and in both the commercial and defense segments of the aerospace industry, levels of air travel, financial condition of commercial airlines, the impact of weather conditions and natural disasters and the financial condition of our customers and suppliers; (2) challenges in the development, production, delivery, support, performance and realization of the anticipated benefits of advanced technologies and new products and services; (3) the scope, nature, impact or timing of acquisition and divestiture or restructuring activity, including the pending acquisition of Rockwell Collins, including among other things integration of acquired businesses into United Technologies» existing businesses and realization of synergies and opportunities for growth and innovation; (4) future timing and levels of indebtedness, including indebtedness expected to be incurred by United Technologies in connection with the pending Rockwell Collins acquisition, and capital spending and research and development spending, including in connection with the pending Rockwell Collins acquisition; (5) future availability of credit and factors that may affect such availability, including credit market conditions and our capital
structure; (6) the timing and scope of future repurchases of United Technologies» common stock, which may be suspended at any time due to various factors, including market conditions and the level of other investing activities and uses of cash, including in connection with the proposed acquisition of Rockwell; (7) delays and disruption in delivery of materials and services from suppliers; (8) company and customer - directed cost reduction efforts and restructuring costs and savings and other consequences thereof; (9) new business and investment opportunities; (10) our ability to realize the intended benefits of organizational changes; (11) the anticipated benefits of diversification and balance of operations across product lines, regions and industries; (12) the outcome of legal proceedings, investigations and other contingencies; (13) pension plan assumptions and future contributions; (14) the impact of the negotiation of collective bargaining agreements and labor disputes; (15) the effect of changes in political conditions in the U.S. and other countries in which United Technologies and Rockwell Collins operate, including the effect of changes in U.S. trade policies or the U.K.'s pending withdrawal from the EU, on general market conditions, global trade policies and currency exchange rates in the near term and beyond; (16) the effect of changes in
tax (including U.S. tax reform enacted on December 22, 2017, which is commonly referred to as the Tax Cuts and Jobs Act of 2017), environmental, regulatory (including among other things import / export) and other laws and regulations in the U.S. and other countries in which United Technologies and Rockwell Collins operate; (17) the ability of United Technologies and Rockwell Collins to receive the required regulatory approvals (and the risk that such approvals may result in the imposition of conditions that could adversely affect the combined company or the expected benefits of the merger) and to satisfy the other conditions to the closing of the pending acquisition on a timely basis or at all; (18) the occurrence of events that may give rise to a right of one or both of United Technologies or Rockwell Collins to terminate the merger agreement, including in circumstances that might require Rockwell Collins to pay a termination fee of $ 695 million to United Technologies or $ 50 million of expense reimbursement; (19) negative effects of the announcement or the completion of the merger on the market price of United Technologies» and / or Rockwell Collins» common stock and / or on their respective financial performance; (20) risks related to Rockwell Collins and United Technologies being restricted in their operation of their businesses while the merger agreement is in effect; (21) risks relating to the value of the United Technologies» shares to be issued in connection with the pending Rockwell acquisition, significant merger costs and / or unknown liabilities; (22) risks associated with third party contracts containing consent and / or other provisions that may be triggered by the Rockwell merger agreement; (23) risks associated with merger - related litigation or appraisal proceedings; and (24) the ability of United Technologies and Rockwell Collins, or the combined company, to retain and hire key personn
tax (including U.S.
tax reform enacted on December 22, 2017, which is commonly referred to as the Tax Cuts and Jobs Act of 2017), environmental, regulatory (including among other things import / export) and other laws and regulations in the U.S. and other countries in which United Technologies and Rockwell Collins operate; (17) the ability of United Technologies and Rockwell Collins to receive the required regulatory approvals (and the risk that such approvals may result in the imposition of conditions that could adversely affect the combined company or the expected benefits of the merger) and to satisfy the other conditions to the closing of the pending acquisition on a timely basis or at all; (18) the occurrence of events that may give rise to a right of one or both of United Technologies or Rockwell Collins to terminate the merger agreement, including in circumstances that might require Rockwell Collins to pay a termination fee of $ 695 million to United Technologies or $ 50 million of expense reimbursement; (19) negative effects of the announcement or the completion of the merger on the market price of United Technologies» and / or Rockwell Collins» common stock and / or on their respective financial performance; (20) risks related to Rockwell Collins and United Technologies being restricted in their operation of their businesses while the merger agreement is in effect; (21) risks relating to the value of the United Technologies» shares to be issued in connection with the pending Rockwell acquisition, significant merger costs and / or unknown liabilities; (22) risks associated with third party contracts containing consent and / or other provisions that may be triggered by the Rockwell merger agreement; (23) risks associated with merger - related litigation or appraisal proceedings; and (24) the ability of United Technologies and Rockwell Collins, or the combined company, to retain and hire key personn
tax reform enacted on December 22, 2017, which is commonly referred to as the
Tax Cuts and Jobs Act of 2017), environmental, regulatory (including among other things import / export) and other laws and regulations in the U.S. and other countries in which United Technologies and Rockwell Collins operate; (17) the ability of United Technologies and Rockwell Collins to receive the required regulatory approvals (and the risk that such approvals may result in the imposition of conditions that could adversely affect the combined company or the expected benefits of the merger) and to satisfy the other conditions to the closing of the pending acquisition on a timely basis or at all; (18) the occurrence of events that may give rise to a right of one or both of United Technologies or Rockwell Collins to terminate the merger agreement, including in circumstances that might require Rockwell Collins to pay a termination fee of $ 695 million to United Technologies or $ 50 million of expense reimbursement; (19) negative effects of the announcement or the completion of the merger on the market price of United Technologies» and / or Rockwell Collins» common stock and / or on their respective financial performance; (20) risks related to Rockwell Collins and United Technologies being restricted in their operation of their businesses while the merger agreement is in effect; (21) risks relating to the value of the United Technologies» shares to be issued in connection with the pending Rockwell acquisition, significant merger costs and / or unknown liabilities; (22) risks associated with third party contracts containing consent and / or other provisions that may be triggered by the Rockwell merger agreement; (23) risks associated with merger - related litigation or appraisal proceedings; and (24) the ability of United Technologies and Rockwell Collins, or the combined company, to retain and hire key personn
Tax Cuts and Jobs Act of 2017), environmental, regulatory (including among other things import / export) and other laws and regulations in the U.S. and other countries in which United Technologies and Rockwell Collins operate; (17) the ability of United Technologies and Rockwell Collins to receive the required regulatory approvals (and the risk that such approvals may result in the imposition of conditions that could adversely affect the combined company or the expected benefits of the merger) and to satisfy the other conditions to the closing of the pending acquisition on a timely basis or at all; (18) the occurrence of events that may give rise to a right of one or both of United Technologies or Rockwell Collins to terminate the merger agreement, including in circumstances that might require Rockwell Collins to pay a termination fee of $ 695 million to United Technologies or $ 50 million of expense reimbursement; (19) negative effects of the announcement or the completion of the merger on the market price of United Technologies» and / or Rockwell Collins» common stock and / or on their respective financial performance; (20) risks related to Rockwell Collins and United Technologies being restricted in their operation of their businesses while the merger agreement is in effect; (21) risks relating to the value of the United Technologies» shares to be issued in connection with the pending Rockwell acquisition, significant merger costs and / or unknown liabilities; (22) risks associated with third party contracts containing consent and / or other provisions that may be triggered by the Rockwell merger agreement; (23) risks associated with merger - related litigation or appraisal proceedings; and (24) the ability of United Technologies and Rockwell Collins, or the combined company, to retain and hire key personnel.
It'll be
interesting if the Republicans face the kind of blowback that the Trudeau government did; while the plan technically cuts the taxation rate on such «pass - through»
structures, it has the potential to actually raise
taxes for a sizeable proportion of those companies:
This
structure is commonly used by corporations as
interest, a
tax - deductible expense, is maximized.
It did this by allowing banks, investment banks, and insurance companies to deduct half of the lender's
interest income in computing their own corporate
taxes for loans or
structured bonds to corporations to access credit to finance ESOPs for broad groups of employees.
Investors can look at this to see how the company is doing operationally, regardless of its capital
structure (
interest payments) or
taxes.
They entail significant risks that can include losses due to leveraging or other speculative investment practices, lack of liquidity, volatility of returns, restrictions on transferring
interests in a fund, potential lack of diversification, absence and / or delay of information regarding valuations and pricing, complex
tax structures and delays in
tax reporting, less regulation and higher fees than mutual funds.
«We are very
interested and working strategically to make sure that we take the necessary steps if the federal government does modify the
structure of the
tax credits,» says Alphonso David, who serves as Cuomo's chief counsel.
The city will extend property
tax deadlines
interest free — and may even provide a refund on property
taxes already assessed — for
structures badly damaged by Hurricane Sandy, a statement today from the office of Mayor Michael Bloomberg said.
«We are very
interested and working strategically to make sure that we take the necessary steps if the federal government does modify the
structure of the
tax credits,» David said.
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A properly
structured investment portfolio can let you take advantage of the low
tax rate on capital gains and dividend income while sheltering your higher -
taxed interest income in your RRSP.
It's also exempt from certain
taxes depending on your company's
structure (i.e. Self - Employment
Tax, SS, FICA, Medicare, etc) and the interest is tax deductible to the busine
Tax, SS, FICA, Medicare, etc) and the
interest is
tax deductible to the busine
tax deductible to the business.
If the investment is
structured correctly, the investor will not have a
tax consequence until the end of the program, and then only portioned out strategically to avoid «bracket creep» (look for profit instruments, not fixed rate products where you pay
interest on an accrual basis).
To encourage their use, the new law made any
interest or capital gains earned on the annuity within a
structured settlement
tax free.
This enables the analyst to compare companies with different capital
structures, since
interests and
tax issue affect «normal» earnings (EPS).
And boy, this approach can deliver — what emerges from the mist can really amaze sometimes... Remember, most writedowns, «compliance»,
interest (/ capital
structuring),
taxes etc. happen at the corporate level.
Next I assume the same
interest expense on the inherited
structured finance (assuming they pay off the «bridge loan»), rounded up slightly, to $ 60 million, and capex at about 20 % greater than depreciation just to be safe, and we get to cash flow (CF) before
taxes of about $ 120 million.
With capital gains
taxed at a lower rate than
interest, we advise you to
structure your investments to profit from that favourable
tax treatment.
@Daniel S. — I only recently learned about this
structure when Dimensional Fund Advisors (DFA) was
interested in launching a version of their U.S. equity fund that could only be held in RRSPs, and was also exempt from foreign withholding
taxes.
If dividend
tax relief is enacted, smart financiers are likely to try to
structure Preferreds where the «dividends» are entitled to an
interest deduction at the corporate level but which pay to the security holder a
tax exempt dividend.
I work with clients and their lawyers to help
structure deals that work in their best
interests, which usually means maximizing the amount they can end up with on a sale, and protecting them against surprise
tax consequences.
We assist issuers, borrowers and underwriters of public finance transactions with the federal and state
tax aspects of
structuring debt obligations to pay
tax - exempt
interest or provide
tax credits to investors.
Advising a firm of accountants about the
tax implications of a complex double partnership
structure, which was required to meet their client's commercial needs in relation to the holding of certain real estate
interests.
Establishing offshore trust
structures for numerous clients prior to the clients becoming deemed domiciled in the UK, including advising on associated issues such as the UK
tax treatment of carried
interest in private equity funds.
The new legislation may affect SQP's desirability as investment vehicles, especially in private equity and property investment fund
structures as the traditional advantages of SQPs — such as separate legal personality and
tax transparency — will need to be weighed against the public disclosure of those individuals who hold a controlling
interest, directly or indirectly, in the SQP.
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interest, insurance, life insurance, second to die insurance Tagged estate
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As long as owners are acquiring or disposing of fractional
interests in a like property, this innovative
structure complies with Section 1031 of the Internal Revenue Code, so owners can defer all capital gains and recapture
taxes.
The
Structured Sale can be a very effective
tax - deferral strategy for the sale or disposition of real estate, business
interests or other personal property.
An investor can use a beneficial
interest in a properly
structured DST (Delaware Statutory Trust) as replacement property in a 1031
tax deferred exchange.
Other critical considerations including
tax treatment, diversification, cash flow,
interest rate sensitivity, volatility and valuations Which
structure is attracting the greatest capital flows and what's the overall outlook for each?
They actually own an
interest in the legal entity, which is a personal property
interest and not a real property
interest, and therefore they do not have the ability to
structure and complete a
tax - deferred exchange.