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8/18/2008 11:57:12 AM EST
Taxation of Securities Transactions
This publication has been fully updated to keep you abreast of recent federal court decisions and IRS rulings and releases affecting the taxation of securities transactions. Topics covered include: (1) Regulatory Relief. The step transaction doctrine permits the IRS to attempt to collapse a multi-step transaction into fewer steps in order to recharacterize the tax treatment of the transaction. (2) Long-term Contract Accounting. One of the issues that will come up from time to time is the question of what happens when there is a mid-contract transfer of a contract reported using the long-term contract method of accounting. (3) “Killer B” Transactions. This is where a subsidiary purchases stock of a parent corporation, and either or both is a foreign corporation, after which the subsidiary uses the parent stock to acquire stock or assets of a target corporation.
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