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

Posted: 18 Sep 2004  

Douglas A. Kahn

University of Michigan Law School

Jeffrey Sean Lehman

New York University – Shanghai

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.

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: https://ssrn.com/abstract=592881

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

New York University – Shanghai ( email )

1555 Century Ave
Pudong, Shanghai 200122
China

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