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Technology Stocks : Qualcomm Incorporated (QCOM) -- Ignore unavailable to you. Want to Upgrade?

To: engineer who wrote (10961)	5/29/1998 2:50:00 AM
From: GO*QCOM	Read Replies (1) \| Respond to of 152472

YEAH!QUALCOMM dose meet the five year rule there but how about the rest of the companies in the portfolio?I wonder what is going to happen with NEXTWAVE.Will they be given some new and better footing due to a ten percent exposure in the traded new spin off.They have to make some important decisions soon to comply with the FCC.I think this whole thing is going to be great for all concerned including us the shareholders.

To: engineer who wrote (10961)	5/29/1998 11:08:00 AM
From: Snake	Respond to of 152472

With regard to the 5 year rule under 355 of the Internal Revenue Code, the analysis is much more complex than can be given here on SI. One big issue is whether the holding of strategic investments qualifies as an active business or is merely an investment. There are Treasury Regulations, IRS Rulings and so forth looking at various facts. This is one area that QCOM's tax department and tax advisors are probably looking at. Also, if I remember correctly, it is almost always advisable to get a ruling from the IRS dictating that the treatment will be tax-free.