Section 90 ?Solely-for-Voting Stock? Requirement

LibraryBusiness Transitions 2009 Supp

The Internal Revenue Service (IRS) issued final rules on transfers of assets or stock following a tax-free I.R.C. § 368(a) reorganization. Treas. Reg. § 1.368-2(k); T.D. 9396, 2008-22 I.R.B. 1026; 73 Fed. Reg. 26,322–26,325 (May 9, 2008). The rules deny safe harbor protection when transfers are made to former shareholders in consideration for proprietary interests in the acquired or surviving corporations. These later transfers outside the safe harbor may jeopardize the continuity-of-interest requirement...

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