Subscribe to the Tax Headline RSS feed | Subscribe to the Tax Headline feed via EmailANALYSIS: When Will Preliminary Distributions Impact Continuity of Interest?
April 6, 2010 in Daily Tax Report · Leave a Comment
In order for a transaction to qualify as a “reorganization,” it must, among other things, exhibit “continuity of interest” (COI); in fact, Treasury Regulations Section 1.368-1(b) provides that “requisite to a reorganization under the Internal Revenue Code are a continuity of business enterprise …
