(A) Year of first transfer. Except as provided in subsection (c) (1) (iii) (B) of this Section, the U.S. contemptuous must report any understandable benefit recognized in accordance with section (c) (1) (i) of this Section on an amended federal income tax return for the taxation year of the original transfer. The amended declaration must be submitted no later than the 90th day following the date on which the award recognition event takes place. (10) Deconsolidation. A deconsolidation of the American despisor is not a triggering event if the American despicer enters into a new profit accounting agreement. (i) A statement that the document constitutes an agreement of the American despisor must be seized in accordance with the requirements of this section. (i) any provision or other event identified in a new profit accounting agreement as the triggering event referred to in paragraph (k)(14)(iii) of this Division; and (i) General rule. A new award recognition agreement concluded in accordance with this Article replaces the existing award recognition agreement, which ends without further effect. The term of the new earnings recognition agreement is the remaining term of the existing earnings recognition agreement. The prize amount subject to the new Prize Recognition Agreement shall be equal to the prize amount subject to the existing Award Recognition Agreement, less any prize recognised in accordance with paragraph (c) (1) (i) of this Section in relation to the existing Prize Recognition Agreement as a result of the winnings recognition event leading to the new Earnings Recognition Agreement. The new earnings recognition agreement may be subject to the conditions and requirements of this Section to the same extent as the existing earnings recognition agreement. For example, a triggering event related to the new profit recognition agreement typically includes a sale of the transferred shares or securities or of almost all of the assets of the transferred company.
However, if the transferred shares are cancelled or withdrawn due to the sale or other event leading to the new profit recognition agreement (e.g. B due to a liquidation in which the transferred foreign company is the distributed company (within the meaning of Article 334(b)(2)), or a reorganization of assets in which the foreign acquiring company is the acquiring company), the transferred share is not subject to the new Profit Realization Agreement. (a) Scope. This section contains the terms of a profit recognition agreement entered into by a U.S. person under Section 1.367(a)-3(b) to (e) in connection with a transfer of shares or securities to a foreign corporation under a stock exchange that would otherwise be subject to Section 367(a)(1). .