Examples of Intercompany Obligation in a sentence
First, if a transaction actually involves an Intercompany Obligation, there is a direct realization and no need for the “indirect” clause.
Comparison of the Intercompany Obligation Rules Under Former Treas.
For example, if a transaction involves a member obligation that is held by a person or entity that is not a member of the group, § 1.1502- 13(g) has no application at all because the obligation is not an Intercompany Obligation.
Accordingly, for Federal income tax purposes, the sale of the Benefits preferred stock is treated as follows: under § 1.1502-13(g)(3)(ii), Sub2 is treated as having satisfied its Intercompany Obligation for $c immediately before Parent’s sale of the Benefits voting preferred stock.
In fact, the only apparent accomplishments were the creation of high basis, low value stock and the sale of that stock in a transaction expected to escape characterization as a transaction with respect to an Intercompany Obligation.