In a Texas Comptroller's Decision, an Administrative Law Judge determined that a taxpayer could not reduce its surplus by the amount of pushed down debt because GAAP did not require the taxpayer's parent corporation to push down the debt and the Texas statute appears to only permit reduction of a taxpayer's surplus by debt belonging to the taxpayer in question, not by debt that belongs to the parent corporation of the taxpayer. Comptroller's Decision No. 28,919, 1995 Tex. Tax LEXIS 261 (June 13, 1995). Furthermore, in another Comptroller's Decision, it was determined that a guarantee of the parent's acquisition debt would not be sufficient to cause the pushed down debt to reduce the taxpayer's surplus. Comptroller's Decision No. 24,931, 1992 Tex. Tax LEXIS 74 (Apr. 3, 1992). 1. Mirror Debt. One "push down' strategy that might be helpful would be to use "mirror" debt. The use of mirror.
guarantees or pledges its assets as collateral for [Holding's] debt. " "Push Down" Basis of Accounting for Parent Company Debt Related to Subsidiary Acquisition, SEC Staff Accounting Bulletin No. 73 (Dec. 30, 1987). In situations where a corporation has incurred debt in connection with its acquisition of stock of another corporation and these criteria are not met or where the SEC rules are not applicable to the transaction, push down of debt, while not required, is still an acceptable accounting method. Some corporations have, as an accounting practice, simply placed Holding's interest expense on Target's books and records. The tax agency may argue that this type of bookkeeping self help can have no tax effect. The taxpayer, however, should demonstrate that in economic reality which should be controlling Holding's lenders' perception (which is completely accurate) was, and is, that Target's assets and operations were, and are, the only sources available for servicing the Nike Women Air Max Thea debt. Thus, accurate accounting (including tax Womens Nike Air Max Gray
accounting) requires the matching of expenses with income directly related to them and, here, the direct relation is obvious: Target's assets and income are really paying the interest expenses (and the principal). The use of push down accounting to push down the debt by changing book entries can also affect taxes based on capital stock. If the debt is placed on Target's books as an intercompany payable to Holding, the tax agency might argue that the debt is part of Target's capital base. Code [sections] 40 14 41(b)(4). Speedring, Inc. , Nike Air Max Womens White And Grey
F. 95 237, F. 95 288, 1996 Ala. Tax LEX IS 65 (1996). See also Pechiney Corp. v. State of Alabama, Department of Revenue, Admin. L. Div. , Docket No. F. 96 106 (Jan. 16, 1997) (in which an Administrative Law Judge used the same reasoning to determine that a parent corporation did not have to include in its capital base amounts that had been loaned to two subsidiaries so that they could repurchase their outstanding debt).
e proceeds of a debt or equity offering of [Target] will be used to retire all or a part of [Holding's] debt; or (3) [Target] Air Max Womens Running Shoes
Alabama Department of Revenue, Docket Nos.
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