February 2021
Intermediate to advanced
156 pages
3h 37m
English
Content preview from Tax Aspects of Corporate Division
Become an O’Reilly member and get unlimited access to this title plus top books and audiobooks from O’Reilly and nearly 200 top publishers, thousands of courses curated by job role, 150+ live events each month,
Start your free trial



The Acquisition of Control of a Corporation Conducting a Business
Introduction
Chapter 5 discussed the 5-year trade or business requirement, and Chapter 6 focused on the continuity of interest requirement. The 5-year requirement was discussed in the context of a corporation that creates a trade or business that is eventually transferred to a subsidiary, and the stock in the subsidiary is distributed to the parent corporation’s shareholders. The following materials are directed at situations where a 5-year holding period requirement is imposed on the corporate shareholder receiving the controlling interest as a distribution. In a sense, this extension of the stock ownership period requirement to the shareholder is another continuity ...