Gain Agreement Statement

(B) Outcome. The transfer of TFC inventories by UST to DC in year 3 is a triggering event in accordance with subsection (j) (4) of this section. However, the transfer does not constitute a triggering event as defined in paragraph (k) (1) (ii) of this Section, when DC enters into a new profit recognition agreement regarding the initial transfer, which DC designates as a U.S. contemptuous for the purposes of this Section. Pursuant to paragraphs (c) (4) (i) and (ii) of this Section, the stock base of TFC and TFD would be increased by the amount of profit recognised if DC is required to win under the new recognition of profits agreement. However, pursuant to subsection (c) (4) (iii) of this Section, there would be no adjustment to the base of DC voting rights shares obtained by UST in Year 3 as a result of such earnings recognition. Alternatively, if the conditions for the application of paragraph k(14) of this Section are met, UST could enter into the new earnings recognition agreement relating to the initial transfer. (iii) the reduction of the stock base. In order to meet the basic requirements of paragraph (o) (1) (i) or (ii) of this Section, the U.S. assignee may reduce the aggregate base of the shares of the transferred foreign company that it received at the time of the initial assignment, with immediate effect prior to the assignment.

To illustrate the rules of this subsection (o) (1) (iii), see subsection (q) (2), example 16, of this section. The U.S. transferor reduces the stock base of the transferred foreign company by adding a return containing the U.S. restitution submitted in a timely manner. Assignor for the fiscal year in which the decision is made, entitled "Election for the reduction of the share base in accordance with Article 1.367 (a)-8 (o)(1)(iii)) and includes - (A) The document of the agreement for the recognition of profits is not submitted in good time in accordance with this section, or when you have given your consent, proceed to the third step. (i) where a profit recognition event occurred during a tax year, a failure to report the profit or to pay additional taxes or interest due in accordance with the terms of the profit recognition agreement; and (2) New recognition agreement. Where a new recognition of profits treaty is entered into in accordance with this Section, the Contemptuous of the United States shall extend the limitation period for tax notices on the initial transfer until the end of the eighth full fiscal year after the fiscal year in which the initial transfer takes place, in accordance with paragraph (f) (1) of this Section. Unless the United States...



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