Tender offer considered an option under Sec. 382 option attribution rule.: An article from: The Tax Adviser

This digital document is an article from The Tax Adviser, published by American Institute of CPA's on July 1, 1992. The length of the article is 757 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: An IRS letter ruling appears to extend the provisions of IRC 382 to consider stock options as stock for purposes of limiting the carryover of net operating losses. This would mean that corporations ability to control their ownership is uncertain, and ownership could change and revert with the expiration of an option. This decision leaves open further interpretations of other types of transactions under section 382.

Citation Details
Title: Tender offer considered an option under Sec. 382 option attribution rule.
Author: Barret Johnson
Publication:The Tax Adviser (Magazine/Journal)
Date: July 1, 1992
Publisher: American Institute of CPA's
Volume: 23 Issue: n7 Page: 463(1)

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