A field theory for options in corporate transactions
Article Abstract:
A general theory of how stock options in corporate reorganizations are taxed would assist tax law practitioners in foreseeing the results of issuing stock options. Two questions affect the development of a stock option theory: whether an option is considered to belong to the issuer's capital structure and whether the option is equity since it has already been exercised. Moreover, Revenue Ruling 82-150 indicates that options may be usable under other Subchapter C conditions. This would cause issuers to partake in lost economic gain in the same manner as any other shareholders.
Publication Name: Journal of Corporate Taxation
Subject: Law
ISSN: 0094-0593
Year: 1992
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"Not quite proper stock": section 351(g) raises a number of new questions
Article Abstract:
Substantial changes in the tax treatment of exchange transactions involving certain types of perferred stock were made by the Taxpayer Relief Act of 1997. IRC section 351 contains new provisions regarding debt-like preferred stock used in generally tax-free corporate exchange transactions under sections 351, 355, 368, and 1036. Gain recognition results from exchanges of nonqualified preferred stock for property. Additional statutory changes or IRS guidance is necessary to clarify the complex new provisions.
Publication Name: Journal of Corporate Taxation
Subject: Law
ISSN: 0094-0593
Year: 1998
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Limited options received in a reorganization
Article Abstract:
The author discuses the tax treatment of limited stock options and warrants granted in connection with tax-free corporate reorganizations. Conflicting federal courts decisions addressing the issue are analyzed, as are IRS regulations granting non-recognition to all stock rights granted in connection with tax-free reorganizations.
Publication Name: Journal of Corporate Taxation
Subject: Law
ISSN: 0094-0593
Year: 2001
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