The Story of the Corporate Reorganization Provisions

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ISBN 13 :
Total Pages : 62 pages
Book Rating : 4.:/5 (129 download)

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Book Synopsis The Story of the Corporate Reorganization Provisions by : Ajay K. Mehrotra

Download or read book The Story of the Corporate Reorganization Provisions written by Ajay K. Mehrotra and published by . This book was released on 2013 with total page 62 pages. Available in PDF, EPUB and Kindle. Book excerpt: Corporate reorganizations occupy a special place in American business tax law. As defined by the Internal Revenue Code, specific corporate reorganizations are granted the benefit of non-recognition treatment. That is, neither corporations nor shareholders recognize the gain or loss on the exchange of securities related to a reorganization, even though such an exchange constitutes a tax realization event. This chapter charts the historical beginnings and early development of this tax benefit for corporate reorganizations.By chronicling the changing political, economic and social contexts from which this tax law arose, this chapter explores how and why the justifications for this corporate tax preference have changed over time. In contrast to past scholarship on this topic, which has generally tended to dwell on singular explanations for the origins of this provision, this chapter contends that the corporate reorganization provisions were created and broadened for historically specific reasons. The explanations and rationales for tax-favored treatment varied over time just as the social, political and economic conditions that supported them changed.To be sure, institutional and bureaucratic inertia played a pivotal part in the persistence of these tax laws. But, ultimately, it was the tractable and protean nature of these justifications and rationales that explain the longevity of these tax rules. The multi-valence of the reorganization provisions across time, in turn, helped to create entrenched political interests that facilitated institutional inertia and frustrated systematic reform. By focusing in greater detail on the historical processes at work during the formative development of this tax law, this chapter seeks to illustrate the contingent evolution of this tax rule; it seeks to show how current policy is the result of past political choices - choices often made among several alternatives.This paper will be published as a chapter in a book entitled Business Tax Stories, to be published by Foundation Press later this year (2005).

Harvard Law School Thesis

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ISBN 13 :
Total Pages : 24 pages
Book Rating : 4.:/5 (831 download)

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Book Synopsis Harvard Law School Thesis by : Roswell Herring Chrisman

Download or read book Harvard Law School Thesis written by Roswell Herring Chrisman and published by . This book was released on 1928 with total page 24 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Qualification of a Transaction as a Corporate Reorganization, Etc. (Us Internal Revenue Service Regulation) (Irs) (2018 Edition)

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Publisher : Createspace Independent Publishing Platform
ISBN 13 : 9781729723708
Total Pages : 40 pages
Book Rating : 4.7/5 (237 download)

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Book Synopsis Qualification of a Transaction as a Corporate Reorganization, Etc. (Us Internal Revenue Service Regulation) (Irs) (2018 Edition) by : The Law The Law Library

Download or read book Qualification of a Transaction as a Corporate Reorganization, Etc. (Us Internal Revenue Service Regulation) (Irs) (2018 Edition) written by The Law The Law Library and published by Createspace Independent Publishing Platform. This book was released on 2018-11-10 with total page 40 pages. Available in PDF, EPUB and Kindle. Book excerpt: Qualification of a Transaction as a Corporate Reorganization, etc. (US Internal Revenue Service Regulation) (IRS) (2018 Edition) The Law Library presents the complete text of the Qualification of a Transaction as a Corporate Reorganization, etc. (US Internal Revenue Service Regulation) (IRS) (2018 Edition). Updated as of May 29, 2018 This document contains final regulations that provide guidance regarding the qualification of a transaction as a corporate reorganization under section 368(a)(1)(F) by virtue of being a mere change of identity, form, or place of organization of one corporation (F reorganization). This document also contains final regulations relating to F reorganizations in which the transferor corporation is a domestic corporation and the acquiring corporation is a foreign corporation (an outbound F reorganization). These regulations will affect corporations engaging in transactions that could qualify as F reorganizations (including outbound F reorganizations) and their shareholders. This book contains: - The complete text of the Qualification of a Transaction as a Corporate Reorganization, etc. (US Internal Revenue Service Regulation) (IRS) (2018 Edition) - A table of contents with the page number of each section

Continuity of Business Enterprise - A Concept Whose Time Has Passed

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ISBN 13 :
Total Pages : 26 pages
Book Rating : 4.:/5 (129 download)

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Book Synopsis Continuity of Business Enterprise - A Concept Whose Time Has Passed by : David F. Shores

Download or read book Continuity of Business Enterprise - A Concept Whose Time Has Passed written by David F. Shores and published by . This book was released on 2009 with total page 26 pages. Available in PDF, EPUB and Kindle. Book excerpt: This article examines the origin and efficacy of the continuity of business enterprise requirement which must be met for a transaction to qualify as a reorganization under section 368 of the Internal Revenue Code. It argues that the requirement emerged from court decisions in the early years of the federal income tax holding that the reorganization provisions were intended by Congress to apply only to transactions involving a mere change in the form of the shareholders' investment. It questions the persuasiveness of these decisions, especially in light of legislative history indicating that Congress had another objective when it adopted the reorganization provisions. The article concludes that the continuity of business enterprise requirement hinders rather than advances this congressional objective, contributes to tax inefficiency in corporate reorganizations, and in many cases is easily circumvented by informed taxpayers. It is therefore suggested that the requirement be abolished or severely restricted.

Corporate Reorganizations

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ISBN 13 :
Total Pages : 586 pages
Book Rating : 4.F/5 ( download)

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Book Synopsis Corporate Reorganizations by :

Download or read book Corporate Reorganizations written by and published by . This book was released on 1936 with total page 586 pages. Available in PDF, EPUB and Kindle. Book excerpt:

"Corporate Business Purpose" in Reorganization

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ISBN 13 :
Total Pages : 32 pages
Book Rating : 4.A/5 ( download)

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Book Synopsis "Corporate Business Purpose" in Reorganization by : Harvey M. Spear

Download or read book "Corporate Business Purpose" in Reorganization written by Harvey M. Spear and published by . This book was released on 1948 with total page 32 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Corporate Reorganisation Law and Forces of Change

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Publisher : Oxford University Press, USA
ISBN 13 : 0198860366
Total Pages : 321 pages
Book Rating : 4.1/5 (988 download)

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Book Synopsis Corporate Reorganisation Law and Forces of Change by : Sarah Paterson

Download or read book Corporate Reorganisation Law and Forces of Change written by Sarah Paterson and published by Oxford University Press, USA. This book was released on 2020-09-18 with total page 321 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book sets out a new approach to identifying and resolving corporate law's normative concerns, establishing new methodology through detailed analysis of key changes in market practice. Paterson adopts a comparative UK/US approach in analysing the process of institutional change, providing important lessons for global legal harmonisation.

ReOrg

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Publisher : Harvard Business Review Press
ISBN 13 : 1633692248
Total Pages : 261 pages
Book Rating : 4.6/5 (336 download)

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Book Synopsis ReOrg by : Stephen Heidari-Robinson

Download or read book ReOrg written by Stephen Heidari-Robinson and published by Harvard Business Review Press. This book was released on 2016-10-25 with total page 261 pages. Available in PDF, EPUB and Kindle. Book excerpt: A Practical Guide in Five Steps Most executives will lead or be a part of a reorganization effort (a reorg) at some point in their careers. And with good reason—reorgs are one of the best ways for companies to unlock latent value, especially in a changing business environment. But everyone hates them. No other management practice creates more anxiety and fear among employees or does more to distract them from their day-to-day jobs. As a result, reorgs can be incredibly expensive in terms of senior-management time and attention, and most of them fail on multiple dimensions. It’s no wonder companies treat a reorg as a mysterious process and outsource it to people who don’t understand the business. It doesn’t have to be this way. Stephen Heidari-Robinson and Suzanne Heywood, former leaders in McKinsey’s Organization Practice, present a practical guide for successfully planning and implementing a reorg in five steps—demystifying and accelerating the process at the same time. Based on their twenty-five years of combined experience managing reorgs and on McKinsey research with over 2,500 executives involved in them, the authors distill what they and their McKinsey colleagues have been practicing as an “art” into a “science” that executives can replicate—in companies or business units large or small. It isn’t rocket science and it isn’t bogged down by a lot of organizational theory: the five steps give people a simple, logical process to follow, making it easier for everyone—both the leaders and the employees who ultimately determine a reorg’s success or failure—to commit themselves to and succeed in the new organization.

The Corporate Reorganization Provision in Senate Bill 3866

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Publisher :
ISBN 13 :
Total Pages : 15 pages
Book Rating : 4.:/5 (651 download)

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Book Synopsis The Corporate Reorganization Provision in Senate Bill 3866 by : Bessie Margolin

Download or read book The Corporate Reorganization Provision in Senate Bill 3866 written by Bessie Margolin and published by . This book was released on 1933 with total page 15 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Corporate Reorganization Rules

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ISBN 13 :
Total Pages : pages
Book Rating : 4.:/5 (81 download)

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Book Synopsis Corporate Reorganization Rules by : Judicial Conference of the United States. Advisory Committee on Bankruptcy Rules

Download or read book Corporate Reorganization Rules written by Judicial Conference of the United States. Advisory Committee on Bankruptcy Rules and published by . This book was released on 1971 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:

Model Rules of Professional Conduct

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Publisher : American Bar Association
ISBN 13 : 9781590318737
Total Pages : 216 pages
Book Rating : 4.3/5 (187 download)

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Book Synopsis Model Rules of Professional Conduct by : American Bar Association. House of Delegates

Download or read book Model Rules of Professional Conduct written by American Bar Association. House of Delegates and published by American Bar Association. This book was released on 2007 with total page 216 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Model Rules of Professional Conduct provides an up-to-date resource for information on legal ethics. Federal, state and local courts in all jurisdictions look to the Rules for guidance in solving lawyer malpractice cases, disciplinary actions, disqualification issues, sanctions questions and much more. In this volume, black-letter Rules of Professional Conduct are followed by numbered Comments that explain each Rule's purpose and provide suggestions for its practical application. The Rules will help you identify proper conduct in a variety of given situations, review those instances where discretionary action is possible, and define the nature of the relationship between you and your clients, colleagues and the courts.

Reorganization clauses in tax treaties

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ISBN 13 : 9789087222277
Total Pages : 442 pages
Book Rating : 4.2/5 (222 download)

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Book Synopsis Reorganization clauses in tax treaties by : Domingo J. Jiménez-Valladolid de l'Hotellerie Fallois

Download or read book Reorganization clauses in tax treaties written by Domingo J. Jiménez-Valladolid de l'Hotellerie Fallois and published by . This book was released on 2013 with total page 442 pages. Available in PDF, EPUB and Kindle. Book excerpt: Reorganization Clauses in Tax Treaties' analyses the tax consequences of corporate reorganizations in the context of tax treaty models and the solutions adopted in the global tax treaties network. The book also proposes solutions to be implemented in the model tax treaties in order to deal with cross-border reorganizations.0 Taxation of mergers and corporate reorganizations is often regarded as one of the most complex aspects of developed tax systems. Contrary to the general realization principle, transfers of assets and liabilities in the course of corporate reorganizations are not taxed when they occur. Instead, recognition of the capital gains arising from such transfers is deferred through different mechanisms under preferential tax regimes with the objective of granting corporate reorganizations a tax neutral treatment.0 However, this tax neutrality might be jeopardized when the effects of corporate reorganizations cross borders. So long as tax treaties do not cater for any special provisions dealing with the effects of corporate reorganizations, cross-border reorganizations will be hampered with the risks of overtaxation, while at the same time global tax neutrality will be compromised due to the inconsistent tax treatment of these transactions from a cross-border perspective.0 Only a few countries have dealt with issues originating from cross-border reorganizations in their tax treaty network. Nonetheless, the solutions adopted in the current situation do not provide satisfactory results when analysing the tax consequences of corporate reorganizations from a global perspective.

Mergers, Acquisitions, and Other Restructuring Activities

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Publisher : Academic Press
ISBN 13 : 0123854857
Total Pages : 784 pages
Book Rating : 4.1/5 (238 download)

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Book Synopsis Mergers, Acquisitions, and Other Restructuring Activities by : Donald DePamphilis

Download or read book Mergers, Acquisitions, and Other Restructuring Activities written by Donald DePamphilis and published by Academic Press. This book was released on 2011-08-22 with total page 784 pages. Available in PDF, EPUB and Kindle. Book excerpt: Two strengths distinguish this textbook from others. One is its presentation of subjects in the contexts wherein they occur. The other is its use of current events. Other improvements have shortened and simplified chapters, increased the numbers and types of pedagogical supplements, and expanded the international appeal of examples.

Corporate Bankruptcy and Financial Reorganization

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Publisher : Aspen Publishing
ISBN 13 : 1454881712
Total Pages : 649 pages
Book Rating : 4.4/5 (548 download)

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Book Synopsis Corporate Bankruptcy and Financial Reorganization by : Richard Squire

Download or read book Corporate Bankruptcy and Financial Reorganization written by Richard Squire and published by Aspen Publishing. This book was released on 2016-10-05 with total page 649 pages. Available in PDF, EPUB and Kindle. Book excerpt: The first edition of Corporate Reorganization in Bankruptcy is designed to teach students the legal and financial principles of business bankruptcy law. The casebook is ideal for second- and third-year law students who are considering a career in business bankruptcy specifically. Each chapter is comprised of case excerpts with questions to prompt discussion and analysis, short readings that summarize the relevant rules, doctrines, and financial concepts, and problems requiring students to apply the legal and financial principles learned from hypothetical fact patterns. With an emphasis on the principles of finance, Corporate Reorganization in Bankruptcy examines each of the major types of investors in a business corporation. In addition, it includes a thorough treatment of Section 363 sales, banking and systemic risk. The purchase of this Kindle edition does not entitle you to receive 1-year FREE digital access to the corresponding Examples & Explanations in your course area. In order to receive access to the hypothetical questions complemented by detailed explanations found in the Examples & Explanations, you will need to purchase a new print casebook.

Reorganizing Failing Businesses

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Publisher : American Bar Association
ISBN 13 : 9781590317143
Total Pages : 1380 pages
Book Rating : 4.3/5 (171 download)

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Book Synopsis Reorganizing Failing Businesses by :

Download or read book Reorganizing Failing Businesses written by and published by American Bar Association. This book was released on with total page 1380 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Creating Value Through Corporate Restructuring

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Publisher : John Wiley & Sons
ISBN 13 : 0470503521
Total Pages : 852 pages
Book Rating : 4.4/5 (75 download)

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Book Synopsis Creating Value Through Corporate Restructuring by : Stuart C. Gilson

Download or read book Creating Value Through Corporate Restructuring written by Stuart C. Gilson and published by John Wiley & Sons. This book was released on 2010-04-05 with total page 852 pages. Available in PDF, EPUB and Kindle. Book excerpt: An updated look at how corporate restructuring really works Stuart Gilson is one of the leading corporate restructuring experts in the United States, teaching thousands of students and consulting with numerous companies. Now, in the second edition of this bestselling book, Gilson returns to present new insight into corporate restructuring. Through real-world case studies that involve some of the most prominent restructurings of the last ten years, and highlighting the increased role of hedge funds in distressed investing, you'll develop a better sense of the restructuring process and how it can truly create value. In addition to "classic" buyout and structuring case studies, this second edition includes coverage of Delphi, General Motors, the Finova Group and Warren Buffett, Kmart and Sears, Adelphia Communications, Seagate Technology, Dupont-Conoco, and even the Eurotunnel debt restructuring. Covers corporate bankruptcy reorganization, debt workouts, "vulture" investing, equity spin-offs, asset divestitures, and much more Addresses the effect of employee layoffs and corporate downsizing Examines how companies allocate value and when a corporation should "pull the trigger" From hedge funds to financial fraud to subprime busts, this second edition offers a rare look at some of the most innovative and controversial restructurings ever.

Holding Company Act. Release

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ISBN 13 :
Total Pages : 428 pages
Book Rating : 4.:/5 (25 download)

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Book Synopsis Holding Company Act. Release by : United States. Securities and Exchange Commission

Download or read book Holding Company Act. Release written by United States. Securities and Exchange Commission and published by . This book was released on 1941 with total page 428 pages. Available in PDF, EPUB and Kindle. Book excerpt: