Committee On Ways And Means Markup On September 25, 1991 of the Financial Institutions Safety And Consumer Choice Act of 1991 (H.R. 6) Jcx-17-91

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An exception to the rule requiring dividend treatment applies to certain transactions in which stock of a bank is transferred to a bank holding company within the meaning of section 2(a) of the Bank Holding Company Act that is newly formed in connection with an acquisition of control of the bank. In such a case, certain minority stockholders of the bank holding company may transfer their bank stock to the bank holding company and receive securities of the bank holding company without dividend t
...reatment. Rather, they generally are taxed on gain, if any, only to the extent the securities received.
Treatment of bank holding companies and their subsidiaries for purposes of the foreign tax credit limitation (Code sec.
864) The United States taxes U.S. persons on their worldwide income, including their income from sources outside of the United States. The foreign tax credit generally allows U.S.
taxpayers to reduce the U.S. tax on their foreign income by the foreign income taxes they pay on that income.


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