Options as a shield against a sec. 382 ownership change.: An article from: The Tax Adviser

by Gilbert D. Bloom

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This digital document is an article from The Tax Adviser, published by American Institute of CPA's on June 1, 1993. The length of the article is 944 words. The page length shown above is based on a typical 300-word page. The article is delivered in HTML format and is available in your Amazon.com Digital Locker immediately after purchase. You can view it with any web browser.

From the supplier: Option exercises that result in ownership change are disregarded under proposed IRS regulations unless they are found to be 'abusive.' There is no discretion on the part of government or the taxpayer. All abusive options will be treated as exercised. A principal purpose is abusive if it manipulates a change in ownership to ease the impact of ownership change by providing the holder with a substantial portion of the stock's ownership attributes, or creates income to absorb corporate losses that occurred prior to the exercise of the option.

Citation Details
Title: Options as a shield against a sec. 382 ownership change.
Author: Gilbert D. Bloom
Publication: The Tax Adviser (Magazine/Journal)
Date: June 1, 1993
Publisher: American Institute of CPA's
Volume: 24 Issue: n6 Page: 350(2)

Distributed by Thomson Gale

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