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Understanding Code Sec. 302 F - CCH

Issue 7 Fall 2003 code Sec. 3021 Depositary Receipts2E-mail Notice4 Inside this issueUnderstanding code Sec. 302 From time to time a tax opinion on a corporateaction includes those mysterious words, subject to the tests of code Sec. 302. Whatdoes it mean? What should you do? This articlewill answer these questions and maybe a few moreyou never even thought for redemptionCode Sec. 302 only applies when a corporationredeems its stock. In this context a redemptionoccurs when a company acquires some or all of itsstock from shareholders in exchange for does not matter whether the company calls theacquisition of its stock a redemption. In fact, 302may apply to a corporate action, like a merger,reverse split or spin-off, that does not appear atfirst glance to involve a redemption, but forpurposes of the code it is still a redemption.

Issue 7 Fall 2003 Code Sec. 302 1 Depositary Receipts 2 E-mail Notice 4 Inside this issue Understanding Code Sec. 302 F rom time to time a tax opinion on a corporate

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Transcription of Understanding Code Sec. 302 F - CCH

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