equity structure shift
Defined in 1 place of the United States Code.
The term “equity structure shift” means any reorganization (within the meaning of section 368). Such term shall not include—
(i) any reorganization described in subparagraph (D) or (G) of section 368(a)(1) unless the requirements of section 354(b)(1) are met, and
(ii) any reorganization described in subparagraph (F) of section 368(a)(1).
Source
- 1994–present26 U.S.C. § 382Internal Revenue Code · Limitation on net operating loss carryforwards and certain built-in losses following ownership change · for purposes of this section
To the extent provided in regulations, the term “equity structure shift” includes taxable reorganization-type transactions, public offerings, and similar transactions.
Source
- 1994–present26 U.S.C. § 382Internal Revenue Code · Limitation on net operating loss carryforwards and certain built-in losses following ownership change · for purposes of this section