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- Title
The Check-and-Merge: A Viable Answer to Cross-entity Merger?
- Authors
Percopo, Joseph M.
- Abstract
The article discusses the prohibition of taxpayers from being able to attain nonrecognition treatment in an entity reclassification due to the failure of the Internal Revenue Law to permit transaction in cross-entity mergers in the U.S. It notes that the application of a cost basis approach in the acquisition of assets will result from nonrecognition of the step transaction doctrine. It mentions that tax-free treatment can be provided by better comprehension of cross-entity mergers.
- Subjects
UNITED States; MERGERS &; acquisitions law; INTERNAL revenue law; TAX basis; STEP transaction doctrine
- Publication
Florida Bar Journal, 2011, Vol 85, Issue 7, p40
- ISSN
0015-3915
- Publication type
Article