Learn how to determine if the principal purpose of an acquisition of control is tax avoidance.
Under section 269(a), net operating loss carryovers or credits may be totally disallowed in the case of control acquisitions principally motivated by tax avoidance purposes. Congress enacted the current version of section 382 in 1986 and made it clear that the legislative history of section 269 continues to apply. Thus, a loss corporation undergoing a debt restructuring must contend with section 269, as well as section 382. This white paper reviews how these regulations may apply to disallow a loss and discusses how aa governmental entity in interest may prevent confirmation of a bankruptcy plan if the principal purpose of the plan is tax avoidance.
You can Login to access if you are already registered.
Thank You!
Download White PaperMore Program Information
