Through a lens darkly: proposed "C" reorganization regulations clear up the Bausch & Lomb problem
Article Abstract:
The author discusses IRS regulations governing subchapter C corporation reorganizations under its common sense approach rather than its former position from the Bausch & Lomb Optical Co. v. Commissioner decision.
Publication Name: Journal of Corporate Taxation
Subject: Law
ISSN: 0094-0593
Year: 2000
User Contributions:
Comment about this article or add new information about this topic:
Form and function in stock acquisitions followed by liquidations and mergers
Article Abstract:
The classification of corporate reorganizations under IRC section 368(a)(1) would appear to allow corporations to use liquidations or mergers freely following a corporate acquisition while still maintaining the transaction's tax-free character, but IRS authority for such planning is not altogether clear. Revenue Ruling 67-274 appears to suggest that, with proper planning, corporations can meet the statutory requirements for either a B or a C reorganization. Characterization and tax treatment seems to depend on whether the IRS decides that a sequence of transactions are part of one plan of reorganization.
Publication Name: Journal of Corporate Taxation
Subject: Law
ISSN: 0094-0593
Year: 1997
User Contributions:
Comment about this article or add new information about this topic:
New wine in old skins: interaction of new COBE regulations and the substantially all requirement
Article Abstract:
The author reviews the new regulations regarding continuity of business enterprise considerations in assessing tax for corporate reorganizations. He investigates how these conflict with the continuing "substantially all" requirement for tax-free reorganizations.
Publication Name: Journal of Corporate Taxation
Subject: Law
ISSN: 0094-0593
Year: 1999
User Contributions:
Comment about this article or add new information about this topic:
- Abstracts: A court revolution brewing? Justices tinker with the federalism trend, but watch out next term. New federalism litmus; rulings, orals show findings by Congress key focus of justices
- Abstracts: Revenue procedure formalizes model correction methods for Employee Plans Compliance Resolution System, excluding the TVC program
- Abstracts: The pen gains power; free-lancers fight to retain rights over republishing their work. Righting victims' rights; activists seek cause-of-action clauses for noncompliance
- Abstracts: New approaches to pro bono; lawyers can help kids in the courtroom - or down on the farm. First-class delivery; innovations increase access to CLE programs
- Abstracts: The effect of a violation of the LMRDA on the outcome of an election. How to hold a union election and stay out of trouble