Continuity in a split-off - why so strict?
Article Abstract:
The author discusses the IRS field service advice memorandum 199929013, regarding the continuity of interest in IRC section 355 distributions in corporate split-offs.
Publication Name: Journal of Corporate Taxation
Subject: Law
ISSN: 0094-0593
Year: 2000
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Outbound transfers of domestic stock and the substantiality requirement
Article Abstract:
The author discusses IRC letter ruling 199929039, regarding an exception to the IRC section 367(a) override recognition of gain or loss rule, that of outbound stock transfers by a domestic corporations.
Publication Name: Journal of Corporate Taxation
Subject: Law
ISSN: 0094-0593
Year: 2000
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A "hunch" about LTR 199935042
Article Abstract:
The author discusses the possible demise of the continuity of shareholder interest in the IRS' letter rulling 199935042.
Publication Name: Journal of Corporate Taxation
Subject: Law
ISSN: 0094-0593
Year: 2000
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