'Continuity of Business Enterprise' Requirement

Continuity of Business Enterprise Doctrine in Need of Regulation

The continuity of business enterprise (COBE) doctrine emerged from case law and is regarded as a “spinoff of the continuity of interest doctrine ...

Continuity Of Business Enterprise Doctrine - Investopedia

The doctrine holds that, in order to qualify as a tax-deferred reorganization, the acquiring entity must either continue the target company's historic business ...

Continuity of Business Enterprise Requirement - Wood LLP

The continuity of business enterprise requirement requires only that the issuing corporation must continue a significant line of business.

Continuity of Business Enterprise Requirement for Corporate ...

This requirement ensures that qualifying reorganizations are limited to readjustments of continuing interests in property under a modified corporate form. More.

Continuity of Business Enterprise (COBE) - Blue J

Continuity of Business Enterprise (COBE) ... Generally, any gain recognized on the sale or exchange of property is taxable, but the Internal Revenue Code (IRC) ...

Continuity of Business Enterprise Requirement for Section 355 ...

Continuity of Business Enterprise Requirement for Section 355 Distributions ... Presumably, the same continuity of business enterprise test applies to both the ...

Continuity of business enterprise - Vocab, Definition, and Must Know ...

If a corporation fails to meet the continuity of business enterprise requirement during a reorganization, it faces significant tax consequences. The lack of ...

26 CFR § 1.368-1 - Purpose and scope of exception of ...

(i) The continuity of business enterprise requirement is satisfied if P uses a significant portion of T's historic business assets in a business. (ii) A ...

Continuity Of Business Enterprise (COBE) - United States - Mondaq

If the acquired company had more than one line of business, COBE only requires that the acquiring company continue a significant line. The ...

'Continuity of Business Enterprise' Requirement - Tax Notes

In those cases, your office proposes to hold that the continuity of business enterprise requirement is not satisfied when a personal holding company with a ...

continuity of business enterprise definition - LSD.Law

Continuity of business enterprise is a rule that applies to mergers and acquisitions. It states that the acquiring company must continue the target ...

THE NEW CONTINUITY OF INTEREST AND CONTINUITY - Steptoe

The regulations provide that, in order to satisfy the continuity of business enterprise requirement, the issuing corporation must either (i) continue a ...

td8760.pdf - IRS

requirement and the continuity of business enterprise requirement. A. Continuity of Interest. The purpose of the continuity of interest requirement is to.

The Continuity Of Interest And Continuity Of Business Enterprise ...

In January 1998, Treasury issued final continuity of†interest and continuity of business enterprise regulations under†section 368. 1 Although these regulations ...

Continuity of Business Enterprise - A Concept Whose Time Has ...

The article concludes that the continuity of business enterprise requirement hinders rather than advances this congressional objective ...

IRS Eases Restrictions on Tax-Free Reorganizations - Venable LLP

Simply stated, the continuity of interest doctrine requires target corporation shareholders to retain half of the stock that they received in a tax-free ...

Mere Change? 'F' Reorganization Qualifies in Spite of Change in Plan

Continuity of Business Enterprise (“COBE”) requirement—Continuity of business enterprise requires that the issuing corporation either continue the target ...

How to Document a Tax-Free D Reorganization With a Split-Off

(2) If the target corporation has more than one line of business, continuity of business enterprise requires only that the issuing corporation ...

MemorandumTM - Akin Gump

that continuity of business enterprise requires more than that the acquiring corporation continue to engage in some business activ- ity. 9 ...

Compliance with the New Continuity of Business Enterprise ...

Thus the battle lines have been drawn, and the validity of requiring enterprise continuity in reorganizations is to be determined in the courts.