IRS declares bond-and-option sales strategy transactions abusive

Article Abstract:

The author discusses IRS notice 99-59, which advises that losses generated by the bond-and-option sales strategy will not be recognized as an allowable loss for tax deduction purposes.

Stock options, Loss deductions

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Exchange of stock in merger following contested tender offer deemed to be reorganization exchange resulting in nonrecognition of loss

Article Abstract:

The US Tax Court's decision in J.E. Seagram Corp. v. Commissioner addressed the continuity of interest and plan of reorganization requirements for IRC section 368(a) corporate reorganization nonrecognition of gain or loss. The taxpayer, Seagram, was arguing that the requirements were not satisfied because it wanted to make use of a $530 million short term capital loss. The Court found that there was a plan of reorganization because the triangular merger was completed pursuant to an agreement between DuPont and Conoco. It also found that the stockholders had a continuing stake.

Corporate reorganizations

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Value of appreciated assets held measure of section 311(d) gain

Article Abstract:

The author discusses the US Tax Court memo on Pope & Talbot, Inc. v. Commissioner regarding the measurement of capital gains recognized under IRC section 311(d).

Capital gains tax

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