Final regs confirm that COI and COBE requirements do not apply to "E" and "F" reorganizations
Article Abstract:
Reg. 1. 368-1(b) is amended with TD 9182 in respect of continuity of interest (COI) and continuity of business enterprise (COBE). According to the revised provisions COI and COBE are not essential for identifying a transaction as one that qualifies as reorganization under Section 368(a) (1) (E) or (F). A brief discussion on the new provision is presented.
Publication Name: Business Entities
Subject: Business
ISSN: 1524-3583
Year: 2005
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"Net value" proposed regulations address insolvency/no net value in various corporate transactions
Article Abstract:
The implications of Internal Revenue Service's (IRS) proposed regulations relating to insolvency and no net value situation in different corporate transactions are discussed. The changes implied for Section 368 and Section 332 pursuant to the proposed amendment are also discussed.
Publication Name: Business Entities
Subject: Business
ISSN: 1524-3583
Year: 2005
User Contributions:
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