(ii) provides the guarantee in paragraph h of this section for any federal tax debt of the U.S. Cedant under the Benefit Recognition Agreement; or (B) result. As DC omitted the fair value of GRA`s FS share, the GRA was not concluded on all the essential points. As a result, it was not possible to submit the ARG on time. As DC knowingly omitted such information, DC`s omission is a deliberate failure to file an ARG in a timely manner. Accordingly, under paragraph p of this section, DC is not eligible for an exemption, the ARG is not considered to be submitted within the time limit for the purposes of paragraph (d) (1) of this section, and DC must recognize the full profit made during the transfer of FS. The same result would occur if DC had included the fair value of the FS share, but had knowingly omitted its GRA tax base. 1. The transfer of TFC stock by the UST to the CEW is an indirect transfer after .

1.367 (a) -3 (d) (1) (iii) (B). In order to obtain non-recognition treatment, UST must therefore enter into a separate recognition agreement under this section with respect to this transfer. 2. With respect to the case recognition agreement submitted for the first transmission of tfD stock, the transfer of the TFC stock to THE FA is a triggering event referred to in paragraph j, paragraph 4, of this section. However, the transfer is not a triggering event if the conditions of the exception under paragraph (14) of this section are met. (F) Alternative facts. Intercompany transaction followed by section 351 Transfer to member. The facts are the same as in paragraph q) (2) (xx) (A) of this section (the facts in this example 20), except that in year 3, in section 351 UST Exchange transfers the entire TFC share to USS in exchange for 10x cash and 80x uss shares. USS is a member of the USP group immediately after the change. The transfer of the TFC share by UST to USS is an intercompany transaction. In accordance with Section 351 (b), the UST must generally recognize the 10x (intercompany) benefit related to the transfer; however, under the provisions of P. 1.1502-13, UST does not take into account the gain of 10x in 3.

In accordance with paragraph (k) (12) of this section, the existing profit recognition agreement (50x) must be divided into usT and USS, as the Intercompany transaction produced an intercompany item.