Busting a "B": why and how, Letter Ruling 9508009.: An article from: The Tax Adviser

This digital document is an article from The Tax Adviser, published by American Institute of CPA's on June 1, 1996. The length of the article is 749 words. The page length shown above is based on a typical 300-word page. The article is delivered in HTML format and is available in your Amazon.com Digital Locker immediately after purchase. You can view it with any web browser.

From the supplier: IRS Letter Ruling 9508009 demonstrates how corporations can intentional avoid tax-free "B" reorganization by violating the "solely for stock" requirement. By paying the target corporation's shareholders for expenses, the acquiring corporation intentionally made the transaction taxable. The result of this letter ruling raises the question of why corporations would consider tax-free treatment undesirable. The acquiring corporation may have wanted a basis step-up, and the seller may have had a realized loss or not been a US taxpayer.

Citation Details
Title: Busting a "B": why and how, Letter Ruling 9508009.
Author: Gilbert D. Bloom
Publication:The Tax Adviser (Magazine/Journal)
Date: June 1, 1996
Publisher: American Institute of CPA's
Volume: 27 Issue: n6 Page: 328(2)

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