Federal tax aspects of corporate reorganizations
Shepards McGraw-Hill, 1988 - Business & Economics - 1100 pages
This volume explores the seven types of reorganizations and their variations. Also covered are such topics as the relationship of S Corporations to reorganizations, foreign reorganizations, liquidations, poison pills, estate freezes and original issue and market discounts.
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The Role of Capital Gain in Reorganizations
Recognition of Gain and Loss
36 other sections not shown
2d Cir 5th Cir acquiring corporation acquisition affd apply assets bailout basis business purpose capital gain carryover cash cent cert denied ch 4 discusses Code common stock Cong continuity of business continuity of interest continuity of proprietary Corp v Commissioner corporation's stock Court creditors debt deduction dividend doctrine earnings and profits example F reorganization fair market value FTACR gain or loss Helvering holders Inc v Commissioner Internal Revenue Service involving liabilities liquidation loss corporation nonrecognition ordinary income original issue discount ownership change parent plan of reorganization poison pill poration preferred stock pursuant qualify recapitalization received recognize gain regulations reorganiza Rev Proc Rev Rul Revenue Act rules shareholders shares solely for voting Stat stock or securities subsidiary substantially supra note target corporation tax avoidance Tax L Rev tax-free taxable taxpayer tion transaction transfer transferor treated triangular merger triangular reorganizations Type B reorganization Type F