Start Tsn liquidating corp v us

Tsn liquidating corp v us

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Thus, one must determinewhen section 356 applies to distributions and redemptions priorto reorganizations.

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This article concludes that the Service should apply a"source of funds" test in determining the application of thesection 356 boot rule.

Although this source of funds test doesnot always yield a clear answer, there is little need for the Service to adopt a more restrictive test for the followingreasons: Under the COI requirement, the historicshareholders of the target corporation must have a continuinginterest in the target assets and target business through theacquisition of the stock of the acquiring corporation.

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Topics generally include the tax treatment of business formation, operations, distributions, liquidations, mergers and acquisitions.