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IRS Guidance Unlocks Value of Troubled Banks, Should Encourage Banking Mergers and Acquisitions  


Author:  Thomas A. Humphreys.; Stephen L. Feldman.; Armin M. Gharagozlou.


Source: Volume 22, Number 03, January/February 2009 , pp.16-21(6)




Journal of Taxation and Regulation of Financial Institutions

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Abstract: 

Amid the credit crisis that has caused the largest failures of financial institutions (including banks, investment banks, and insurance companies) in U.S. history, the Internal Revenue Service has issued guidance that addresses Sections 382 and 597 of the Internal Revenue Code. This guidance includes Notice 2008-83, issued on September 30, 2008, Notice 2008-100, issued on October 14, 2008 and Notice 2008-101, issued on October 14, 2008. These Notices should unlock significant value in troubled banks and should encourage acquisitions of troubled banks by stronger financial institutions.

Keywords: Troubled Assets Relief Program; Capital Purchase Program

Affiliations:  1: Morrison & Foerster LLP; 2: Morrison & Foerster LLP; 3: Morrison & Foerster LLP.

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