Type_A_reorganizations

Type_A_reorganizations - Type A reorganizations: Is 40 or...

Info iconThis preview shows page 1. Sign up to view the full content.

View Full Document Right Arrow Icon
This is the end of the preview. Sign up to access the rest of the document.

Unformatted text preview: Type A reorganizations: Is 40 or 50 percent stock enough to pass the continuity of interest test? The IRS and the Treasury Department are in disagreement over the “continuity of interest” test in a Type “A” reorganization. The IRS feels that 50% should be the minimum, but admits that there is a lesser amount that might be adequate. The Courts have sometimes allowed amounts in the 40’s. Footnote 9 on page 7‐10 refers to the Temporary Regulation that expired earlier this year. This is the first edition in which the authors brought up this Temporary Regulation. ...
View Full Document

Ask a homework question - tutors are online