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.

Stocks, Interest deductions, Distribution

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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.

Recognition of gain or loss (Taxation), Recognized gain or loss (Taxation), Stock transfer

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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.

Stockholders

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