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A Surprising Continuity-of-Interest Ruling

The IRS revisits a long-standing concept, and gives a nod to the practice of using warrants to satisfy the COI test – at least in some circumstances.

September 7, 2010

It used to be that only stock counted on the "plus side" of the continuity-of-interest equation, when it came to figuring out whether a transaction could garner tax-free treatment. But a new private-letter ruling by the Internal Revenue Service revisits the concept, with a surprising result. That is, in the case of so-called G reorganizations, warrants may do the trick as well as stock. Read more...

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