CONTINUITY OF INTEREST

glossary /

CONTINUITY OF INTEREST

continuity of interest.

1. A doctrine covering acquisitive reorganizations whereby a target corporation’s share-holders must retain a share in the acquiring corporation to qualify the exchange as a tax-deferred transaction.

2. A judicial requirement for divisive reorganizations whereby a target corporation’s shareholders must retain an interest in both the distributing and the controlled corporations to qualify the exchange as a tax-deferred transaction. [Cases: Internal Revenue 3677.]

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