0605009 Informal Interpretation

Date

May 5, 2006

Rule

803.9

Staff

Michael Verne

Response/Comments

one fee (see 803.9(c)). If they have other holdings outside of company A two fees.

Original Image File (63.27 KB)

Question

From: (redacted)

Sent: Friday, May 05, 20064:16 PM

To: Verne, B. Michael

Subject:Quick question

Hi Mike. I have a quick and easy question, but Ican't put my finger on the answer right now.

Company A has two UPEs. Company A intends to acquireCompany B in a transaction that is reportable for both of Company A's UPEs. Onefee or two?

Verne, 6. Michael &o 3.5
From:
Sent: 	Fnday, May 05.2006 4.16 PM
To: 	Verne, B Michael
Subject: 	Qu~ckquestion
Hi Mike. I have a quick and easy question, but I can't put my finger on the answer right now.
Company A has two UPEs. Company A intends to acquire Company B in a transaction that is
reportable for both of Company A's UPEs. One fee or two?
Thanks,
This electronic mail and any enclosed documents may contain provisions concerning a federal tax
issue or issues. This electronic mail and any enclosed documents are not intended or written to be
used, and cannot be used, by any taxpayer for the purpose of avoiding penalties that may be
tmposed on any taxpayer by the Internal Revenue Service. For information about this statement,
contact 	or visit our website a	t	-

0605009 Informal Interpretation

Question

Setzen Sie Ihre Recherche in ChatGPT oder Claude fort