IRS Continues Work on Continuity-of-Interest Standard Proposal

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IRS may contemplate further modifications to proposed rules governing the tax treatment of certain reorganizations, even though the proposal already expired once because of IRS inaction, IRS Associate Chief Counsel (Corporate) William Alexander says. IRS in 2007 issued temporary and proposed regulations regarding the continuity-of-interest test used to ascertain whether a transaction is a sale or an Internal Revenue Code Section 368 nonrecognized reorganization. Alexander, speaking at the New York State Bar Association Tax Section's annual meeting, says IRS continues its work to make the proposed rules final but is challenged to put into words the result IRS tax specialists seek to articulate in a final rule.

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