Sunday, June 15, 2008 1:21:14 AM
Very nice post. I think there also has to be a certain percentage continuous ownership from the original company to the resulting entities. If my memory serves, it is like both the resulting entities must maintain at least 50% of the original ownership inorder to not constitute a sale. I believe it is a Form B reorganization under code 355. Now, I'm gonna have to look it up on monday.
If that is true, then the prior post of "just north of 50%" makes sense as this would maintain the desire tax status.
The fair market value thing is bothering me. I may be thinking of the allocation of the cost basis between your old shares and the new spinoff shares once you receive them.
I'm getting thirsty dammit!
Oh yea, everthing is my opinion only. Please make your own decisions and consult your own financial advisors for both investment and income tax issues.
If that is true, then the prior post of "just north of 50%" makes sense as this would maintain the desire tax status.
The fair market value thing is bothering me. I may be thinking of the allocation of the cost basis between your old shares and the new spinoff shares once you receive them.
I'm getting thirsty dammit!
Oh yea, everthing is my opinion only. Please make your own decisions and consult your own financial advisors for both investment and income tax issues.
I'm getting thirsty dammit!
Oh yea, everthing is my opinion only. Please make your own decisions and consult your own financial advisors for both investment and income tax issues.
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