Corporate acquisitions [electronic resource] : D reorganizations / Candace A. Ridgway, Esq., Jones Day, Washington, D.C. ; based on an earlier version by Candace A. Ridgway, Esq. and Larry E. Phillips, Esq., Buchanan Ingersoll and Rooney PC, Pittsburgh, Pennsylvania.
" ... describes the various aspects of the two basic types of transactions that qualify as reorganizations under [section] 368(a)(1)(D) ("D reorganizations")."
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Online Access: |
Law Students, Faculty, and Staff (via Bloomberg Law) |
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Main Authors: | , |
Other title: | D reorganizations Bloomberg Law online Bloomberg Law online. |
Format: | Electronic Website |
Language: | English |
Published: |
[Arlington, Va.] :
Tax Management Incorporated,
[2004]-
|
Series: | Tax management portfolios ;
772-5th. |
Subjects: |
Table of Contents:
- Detailed Analysis. Introduction
- Control of the Acquiring Corporation
- Transfer of Assets
- Distribution Requirement
- Plan of Reorganization
- Business Purpose Doctrine
- Continuity of Business Enterprise
- Continuity of Interest
- Step-Transaction Doctrine
- Liquidation-Reincorporation
- Comparison with Other Reorganizations
- Relationship to Section 351
- Sale of Stock to Related Corporation
- Combining Divisive and Acquisitive Reorganizations
- Tax Treatment of a D Reorganization
- Carryover of Tax Attributes
- Investment Tax Credit Recapture
- Section 306 Stock
- Small Business Corporations
- Foreign Transactions
- Ruling Requests
- Reporting Requirements
- Working Papers.