Letter Ruling 9535053: little ado about something?
Article Abstract:
An IRS ruling in Letter Ruling 9535053 that a series of transactions between family members involving close corporation stock would not result in any recognition of gain or loss also raised a number of issues regarding each of the transaction steps set forth. The plan involved the use of a bank holding corporation to pass the stock value of two controlled subsidiaries into a new holding company. Issues addressed include the consequences of an extraordinary distribution, the characterization of intermediate transactions and the business purpose of the series of transactions.
Publication Name: Journal of Corporate Taxation
Subject: Law
ISSN: 0094-0593
Year: 1996
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Continuity representation discontinued
Article Abstract:
IRS final regulations containing continuity of interest rules applicable to stock dispositions occurring before and after corporate reorganizations extend existing law and create new problems requiring clarifying guidance. The regulations, effective for transactions occurring beginning Jan 29, 1998, contain unclear rules which depart from established IRS treatment of continuity of interest and of business enterprise. The application of attribution rules and new related party rules are unclear and problematic.
Publication Name: Journal of Corporate Taxation
Subject: Law
ISSN: 0094-0593
Year: 1998
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