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Tuesday, June 29, 2010

SubChapter M Tax: irs notice 2010-50 - guideance under 382 for measuring ownership shifts

SubChapter M Tax: irs notice 2010-50 - guideance under 382 for measuring ownership shifts:

"Part III - Administrative, Procedural, and Miscellaneous

SECTION 382(l)(3)(C)

Notice 2010-50

This notice provides guidance under � 382 of the Internal Revenue Code for measuring owner shifts of loss corporations that have more than one class of stock outstanding, and, in particular, regarding the effect of fluctuations in the value of one
class of stock relative to another class of stock (fluctuations in value). It provides interim guidance to the effect that the Internal Revenue Service (IRS) will accept certain methodologies for taking into account or not taking into account fluctuations in value, and identifies one methodology that the IRS views as inconsistent with � 382(l)(3)(C). It also requests comments to assist in the development of future guidance. Any terms and definitions used in this notice have the same meaning as they do in � 382 and the �382 regulations unless otherwise provided in this notice."
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