The Service disagreed, claiming the fees were corporate reorganization
costs that should have been capitalized because the S election produced benefits extending beyond the tax year.
The purpose of the COI requirement is to prevent transactions that resemble sales from qualifying for nonrecognition of gain or loss available in corporate reorganizations
See Mintz and Plumb, "Step Transactions in Corporate Reorganizations
," 12 NYU Institute on Federal Taxation 247 (1954); Chirelstein and Lopata, "Recent Developments in the Step-Transaction Doctrine," 60 Taxes 970 (Dec.
Crystallize Software enables organizations to rapidly implement business change driven by strategic initiatives such as mergers and acquisitions, corporate reorganizations
, divestitures, and eBusiness initiatives.
Like the other types of corporate reorganizations
, Type Ds are also subject to subchapter C's operational rules.
Crystallize Software is the standard that enables organizations to rapidly implement business change driven by strategic initiatives such as mergers and acquisitions, corporate reorganizations
, divestitures, and E-Business in their IT systems.
Since the Supreme Court's decision, there has been considerable concern that IRS personnel would interpret INDOPCO as requiring the capitalization of expenditures unrelated to corporate reorganizations
that have customarily been regarded by taxpayers as currently deductible.
Stander is skilled in corporate reorganizations
and restructuring plans.
a Vancouver-based consulting firm, specializing in corporate finance, debt and equity financing, mergers and acquisitions as well as corporate reorganizations