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The deemed distribution would be added to the basis for a future distribution.
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The Lucasfilm acquisition follows Disney's very successful acquisitions of Pixar and Marvel, which demonstrated the company's unique ability to fully develop and expand the financial potential of high quality creative content with compelling characters and storytelling through the application of innovative technology and multiplatform distribution on a truly global basis to create maximum value.
ENGADGET: Disney acquires Lucasfilm for $4.05 billion, plans more Star Wars movies
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Another important benefit of the NUA strategy is that for any shares not liquidated after distribution, a step up in basis is available at death.
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It plans to buy the new projectors and lease them to cinemas on a per-showing basis, while handling the distribution by satellite.
ECONOMIST: Curtains for celluloid
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These ordering rules are intended to be taxpayer-friendly, as S corporation shareholders would generally prefer to have a distribution treated as a tax-free return of basis than a taxable dividend.
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In other words, only the part of the distribution that represents non-deductible contributions (your cost basis) is tax-free.
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Even if the distribution is subject to a 10% penalty tax, it is only based on the basis of the stock.
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In addition to effectively exempting the most likely basis for a program access dispute, the Sunset Order makes clear that a distribution rival still can bring a complaint under other sections of the Cable Act.
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But they had customers and a distribution setup, so they began offering a full line of computers and accessories on the same basis: rock-bottom prices made possible by keeping costs low.
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But they did have customers and a distribution setup, so they began offering a full line of computers and accessories on the same basis: rock-bottom prices made possible by keeping costs low.
FORBES: You want cables with that?