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U.S. IRS Issues Revenue Procedure on Safe Harbor Methods for Continuity of Interest Determination for Tax-Free Reorganizations

|Approved Changes|United States
United States

The U.S. IRS has issued Revenue Procedure 2018-12, which covers safe harbor methods that taxpayers may use to value certain stock received by a target corporation’s shareholders in a potential (tax-free) reorganization for purposes of determining whether the continuity of interest (COI) requirement is met. These include:

  • Average of the Daily Volume Weighted Average Prices;
  • Average of the Aver…

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