"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.

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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.

Tax Law, Public Finance Activities, Corporate Tax Administration, Laws, regulations and rules, Corporate taxes, Tax administration, Recognition of gain or loss (Taxation), Recognized gain or loss (Taxation)

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