Boot given a shareholder in a merger will now generally be taxed as a capital gain
Article Abstract:
The Supreme Court ruled in the Clark decision that most boot distributions, which result from corporate reorganizations and provide gains to shareholders, should be taxed as capital gains rather than as ordinary income. The decision will affect similar reorganizations, so it will be important to plan for such distributions. Planning guidelines are presented for the following areas: target corporation; acquiring corporation; shareholders; earnings and profits; partial liquidations; installment method; and safe harbors.
Publication Name: Taxation for Accountants
Subject: Business
ISSN: 0040-0165
Year: 1989
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Should the qualified plan distribution election be allowed to expire unexercised?
Article Abstract:
The excise tax on qualified plan benefits can still be limited under an election which is available to certain individuals under Section 4980A. Section 4980A and its provisions are described, showing that ambiguities in the law will cause problems for accountants, possibly for several years to come.
Publication Name: Taxation for Accountants
Subject: Business
ISSN: 0040-0165
Year: 1989
User Contributions:
Comment about this article or add new information about this topic:
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