The ruling treated an intra group sale of stock as if it were a qualified stock purchase, with the result that the assets in the sold corporaiton received a basis step up when the sold corporation was distributed to the shareholders and the original holding company was sold to a REIT that wanted the real estate assets of the original group.
About Jasper L. (Jack) Cummings, Jr.
Jack Cummings is counsel in the Federal Tax Group of Alston & Bird in Raleigh and Washington, D.C. He served as IRS associate chief counsel (corporate) and chair of the Corporate Tax Committee of the ABA Section of Taxation.
About Edward Tanenbaum
Edward Tanenbaum is co-chair of the firm’s Federal & International Tax Group and a member of the firm’s Global Resources & Strategies Committee. Mr. Tanenbaum’s practice consists primarily of planning and structuring tax efficient solutions for cross-border business transactions and investments by foreign multinational corporations and high-net-worth individuals.