A reverse Morris trust is a tax - optimization strategy in which a company wishing to spin off and subsequently sell assets to an interested party can do so while avoiding taxes on any gains from
such asset disposal.
Not exact matches
On March 30, 2015 the Court approved an
asset purchase agreement among Target Canada, Target Brands Inc. and Target Corporation (the U.S. parent company) wherein Target Corporation will purchase a variety of items that use or display intellectual property (
such as shopping carts and exterior signage), and pay the costs of third party removal and
disposal of these items.
Disincorporation Relief allows a company to transfer certain types of
assets (company
assets such as land and buildings, goodwill and other intangible
assets) to its shareholders (who continue to operate the business in an unincorporated form) without the company incurring a corporation tax charge on the
disposal of the
assets.
The problem with this strategy, though convincing in theory, is that there is little incentive for the heads to do so on the current model, which provides inadequate capital for the development of
such arrangements, and constrains these trusts in important ways from attracting and deploying the resources necessary for sustainable school improvement,
such as constraints on the pooling of General Annual Grant funding, accumulation of surpluses, borrowing (whether secured against
assets or on funding agreements), deployment of capital, and acquisition and
disposal of fixed
assets — all inhibit chains from deploying resources where they are needed most.
Sam Payne (Band 3 — Individual Ranking — Restructuring / Insolvency — Midlands) of Harrison Clark Rickerbys assists insolvency practitioners with administrations and
asset disposals, as well as handling contentious matters
such as director disqualification proceedings.
Negotiating and reviewing critical contractual relationships,
such as electric interconnection contracts, power sale contracts,
asset management and optimization contracts, transmission service contracts, power brokering and marketing contracts, steam and thermal energy sale contracts, turbine procurement contracts (including warranty and guaranty provisions), operation and maintenance contracts, ash management and
disposal contracts, and engineering, procurement and construction contracts.
TR's
disposal of legal publishing
assets in northern European markets also ran counter to
such a deal.
... a transaction consisting of the purchase, sale, lease, merger or amalgamation or any other type of acquisition or
disposal of, or the taking of a security interest in respect of, an organization or a portion of an organization or any business or activity or business
asset of an organization and includes a prospective transaction of
such a nature.
Examples of
such circumstances are: When one or more stocks exchanges which provide a basis for valuation for a substantial portion of the
assets of the fund are closed otherwise than for ordinary holidays When, as a result of political, economic, monetary or any circumstances out of our control, the
disposal of the
assets of the unit fund are not reasonable or would not reasonably be practicable without being detrimental to the interests of the remaining unit holders.