Tax-free reorganizations: new definition of continuity.
The Tax Adviser › Vol. 29 Nbr. 4, April 1998
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Summary
The IRS issued on Jan 23, 1998 final regulations effective for transactions beginning on Jan 29, 1998 which provide guidance for satisfying continuity of shareholder interest and business enterprise rules in tax-free reorganizations. Prior judicial and administrative law is overridden by the regulations. The continuity of shareholder interest rules are applied to pre-reorganization stock transfers in IRS-issued proposed and temporary regulations.
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Tax-free reorganizations: new definition of continuity.
On Jan. 23, 1998, the IRS issued final regulations on the satisfaction of the continuity-of-shareholder-interest (COSI) and continuity-of-business-enterprise (COBE) requirements for corporate reorganizations. The final regulations basically adopt the proposed regulations with respect to the impact of pos...
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