Another effort to plug the leaks in section 355
Article Abstract:
It is evident that Congress and Pres Clinton are interested in revising IRC section 355 to combat its use to avoid corporate income taxes, but all the proposed revisions have their own shortcomings. In some widely publicized transactions, parent corporations have created a subsidiary with unwanted assets, spun off the subsidiary, distributed the stock to the parent shareholders, and then used tax-free mergers to sell the subsidiary. Proposals have focused on whether merger talks occurred before the spin-off and whether continuity requirements have been met.
Publication Name: Taxes: The Tax Magazine
Subject: Business
ISSN: 0040-0181
Year: 1997
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What happens when the proposed continuity of shareholder interest regulations become effective?
Article Abstract:
The IRS released proposed regulations under IRC section 368 in December 1996 that will limit the impact of the post-reorganization continuity of shareholder interest test for tax-free corporate reorganizations. The test is satisfied if consideration furnished represents a substantial part of the value or property or stock transferred. The revised test appears to be similar to other anti-abuse regulations that have become increasingly popular at the IRS. Some practitioners believe that scarce resources have forced the IRS to retreat on these issues.
Publication Name: Taxes: The Tax Magazine
Subject: Business
ISSN: 0040-0181
Year: 1997
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Business impact of Conference Committee changes to IRS Restructuring Act
Article Abstract:
Favorable changes to business-related provisions of the IRS Restructuring and Reform Act of 1998 were the product of business community lobbying. Industry lobbying influenced changes to IRC section 1059 regarding recognition of gain on extraordinary dividends in certain redemption transactions. Other provisions influenced by lobbying include small business' stock and employer suppled meals.
Publication Name: Taxes: The Tax Magazine
Subject: Business
ISSN: 0040-0181
Year: 1998
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