IRS Issues Private Letter Rulings to Mutual Funds on Tax-Free Reorganizations, Providing Needed Guidance on the 'Continuity of Business Enterprise' Requirement.
Mondaq Business Briefing › Nbr. 2005, January 2005
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Internal Revenue Service
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IRS Issues Private Letter Rulings to Mutual Funds on Tax-Free Reorganizations, Providing Needed Guidance on the 'Continuity of Business Enterprise' Requirement.
On Friday, July 8, 2005, the IRS issued to one of our clients several private letter rulings ("PLRs") to the effect that the combination of mutual funds constitute tax-free reorganizations under Section 368(a)(1)(C) of the Internal Revenue Code. In issuing these PLRs, the IRS provided much needed guidance on the "continuity of business enterprise" requirement that must be satisfied in order for a combination of two operating mutual funds to constitute a tax-free reorganiz...
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