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Tax Opportunities and Issues for Acquirers of Banks Arising Under Section 1261 of the American Recovery and Reinvestment Act of 2009  


Author:  Philip C. Cook.; Charles W. Wheeler.


Source: Volume 22, Number 06, July/August 2009 , pp.24-28(5)




Journal of Taxation and Regulation of Financial Institutions

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Abstract: 

No IRS administrative guidance in recent memory has generated greater public and congressional furor than last year’s attempt to modify rules governing use of losses in acquisitions of failing banks. Despite the furor sparked by Notice 2008-83, banks with grandfathered acquisitions have reason to be pleased with the American Recovery and Reinvestment Act of 2009.

Keywords: ARRA Section 1261; Net unrealized business loss; Recognized build-in loss

Affiliations:  1: Alston & Bird LLP; 2: Alston & Bird LLP.

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