In the high-stakes world of corporate tax strategy, practitioners often assume that if you follow the literal math of a regulation, you’re safe. The recent Tax Court decision in SIH Partners v. Commissioner proves that while the math matters, the underlying intent matters just as much. The case involved a sophisticated dividend arbitrage transaction. The … Read more
Here is a comprehensive list of the legal authorities, statutes, regulations, rulings, cases, and doctrines that support and govern the legality of a Section 351 exchange of securities into an ETF: Internal Revenue Code (IRC) Statutes The foundation of the tax-deferred conversion relies on specific sections of the IRC governing corporate formations and investment companies: … Read more
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