"Regular, normal distributions" and the substantially all requirement
Article Abstract:
The author discusses the tax consequences of IRS' letter ruling 199941046 regarding the meaning of reorganization and the acquiring of stock.
Publication Name: Journal of Corporate Taxation
Subject: Law
ISSN: 0094-0593
Year: 2000
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New wine in old skins: interaction of new COBE regulations and the substantially all requirement
Article Abstract:
IRS regulations under IRC section 368 which contain continuity of business enterprise (COBE) rules concerning corporate reorganizations should be examined in conjunction with the substantially all requirement applicable to types C and D reorganizations and some types of triangular mergers. Inconsistencies in tax treatment and planning difficulties result from the imprecise match of the concepts in the tax-free reorganization context. The usefulness of the newer COBE rules is limited by the IRS's not revising other rules which effectively limit the COBE rules' flexibility.
Publication Name: Journal of Corporate Taxation
Subject: Law
ISSN: 0094-0593
Year: 1999
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