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 Average High-Low Daily Prices; and Average of the Daily Closing Prices. Provided that a reorganization transaction meets certain requirements as set out in the Revenue Procedure, the IRS will not challenge a taxpayer’s use of one of these methods to determine the...