Rev. Rul. 64-250
Rev. Rul. 64-250; 1964-2 C.B. 333
- Code Sections
- LanguageEnglish
- Tax Analysts Electronic Citationnot available
Amplified by Rev. Rul. 2008-18
M , an electing small business corporation within the meaning of section 1371(b) of the Internal Revenue Code of 1954, was reincorporated in a state other than that of original incorporation. The shareholders of M accomplished the reincorporation by organizing a new corporation, N , in the other state and merging M in N . The transaction qualified as a reorganization under section 368(a)(1)(F) of the Code. The surviving corporation, N , also met the requirements for qualification as a small business corporation under section 1371(a) of the Code.
Held , under the facts presented, the reorganization, under section 368(a)(1)(F) of the Code, did not cause a termination of the election under section 1372 of the Code.
- Code Sections
- LanguageEnglish
- Tax Analysts Electronic Citationnot available
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