Abstract

http://ssrn.com/abstract=592881
 


 



Exchanges of Multiple Stocks and Securities in Corporate Divisions or Acquisitive Reorganizations


Douglas A. Kahn


University of Michigan Law School

Jeffrey Sean Lehman


Cornell University


Tax Notes, Vol. 104, No. 13, September 20, 2004

Abstract:     
When a corporate division or acquisitive reorganization involves an exhange of multiple blocks of securities and stocks, an unresolved issue is how the exchanged properties are to be matched in determining the amount of gain recognized and the basis of the acquired properties. Should the exchanged properties be compared in the aggregate, or should the exchange be divided into separate segments? If divided into segments, should each segment be subject to a further division into sub-segments? How should the segmentation be determined? This article examines the different approaches that are possible, the difference in tax consequences attending each approach, and the authors' view of the best solution.

Accepted Paper Series





Not Available For Download

Date posted: September 18, 2004  

Suggested Citation

Kahn, Douglas A. and Lehman, Jeffrey Sean, Exchanges of Multiple Stocks and Securities in Corporate Divisions or Acquisitive Reorganizations. Tax Notes, Vol. 104, No. 13, September 20, 2004. Available at SSRN: http://ssrn.com/abstract=592881

Contact Information

Douglas A. Kahn (Contact Author)
University of Michigan Law School ( email )
625 South State Street
Ann Arbor, MI 48109-1215
United States
734-647-4043 (Phone)
Jeffrey Sean Lehman
Cornell University ( email )
Ithaca, NY 14853
United States
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