Show simple item record

Rationalizing the Taxation of Reorganizations and Other Corporate Acquisitions

dc.contributor.authorSchlunk, Herwig J.
dc.identifier.citation27 Va. Tax Rev. 23 (2007)en_US
dc.description.abstractThis article examines the taxation of human shareholders in the case of mergers and acquisitions. Currently, the relevant law is extraordinarily complex, utterly inconsistent, and in many instances arguably unfair. There are really only two plausible ways to cure these ills. The first would involve moving to a tax system with more fulsome gain recognition, most likely in the form of mark-to-market taxation. This option is not in my opinion feasible (either technically or what is perhaps more important, politically). Accordingly, the second potential cure, moving to a tax system with less gain recognition, merits attention. In this article, I propose such a tax system. In particular, under my proposal, a human shareholder whose stock is sold or exchanged pursuant to a merger or acquisition would be entitled to nonrecognition treatment so long as either (1) he receives stock in the acquiring corporation or (2) he involuntarily receives consideration other than stock in the acquiring corporation but promptly and appropriately reinvests such considerationen_US
dc.format.extent1 PDF (61 pages)en_US
dc.publisherVirginia Tax Reviewen_US
dc.subject.lcshConsolidation and merger of corporations -- United Statesen_US
dc.subject.lcshCorporations -- Taxation -- Law and legislation -- United Statesen_US
dc.titleRationalizing the Taxation of Reorganizations and Other Corporate Acquisitionsen_US

Files in this item


This item appears in the following Collection(s)

Show simple item record