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Fisher v. U.S.: What Does It Mean to Shareholders Who Received Cash in Demutualizations of Insurance Companies?  


Author:  Kevin A. Diehl.


Source: Volume 26, Number 01, Fall 2008 , pp.50-58(9)




Journal of Taxation of Investments

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Abstract: 

Thirty-four mutual insurance companies have demutualized in the last two decades. Numerous taxpayers have been affected by this process. On August 6, 2008, a Court of Federal Claims case, Fisher v. U.S , overturned longstanding IRS rulings regarding the tax treatment (the basis) of stock or cash received in demutualizations. Thus, sophisticated taxpayers and tax professionals alike must consider whether they or their clients should file amended returns.

Keywords: 

Affiliations:  1: Western Illinois University.

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