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Involuntary conversion of stock.

 

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Subject Author Date
Involuntary conversion of stock. SD 08-04-2009
Posted by SD on August 4, 2009, 2:54 pm
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As far as I can tell from the pubs, an involuntary conversion of stock
(i.e. a company buys out, via a tender offer, another company and then
forced shareholders that did not tender their shares to sell), is not
an involuntary conversion for tax purposes. Can somebody please tell
me that I am wrong.

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Posted by Steve Pope on August 4, 2009, 3:09 pm
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>As far as I can tell from the pubs, an involuntary conversion of stock
>(i.e. a company buys out, via a tender offer, another company and then
>forced shareholders that did not tender their shares to sell), is not
>an involuntary conversion for tax purposes. Can somebody please tell
>me that I am wrong.

It's an involuntary conversion (Title 26, Subtitle A, Chapter 1,
Subchapter O, Part III, Sectioh 1033), but since it's a conversion
into similar property, under the General Rule it is not a
tax event. Your basis and holding period are carried over
to the new shares.

Steve

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<< ------------------------------------------------------- >>
<< The foregoing was not intended or written to be used, >>
<< nor can it used, for the purpose of avoiding penalties >>
<< that may be imposed upon the taxpayer. >>
<< >>
<< The Charter and the Guidelines for submitting posts >>
<< to this newsgroup as well as our anti-spamming policy >>
<< are at www.asktax.org. >>
<< Copyright (2007) - All rights reserved. >>
<< ------------------------------------------------------- >>

Posted by Alan on August 4, 2009, 3:26 pm
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Steve Pope wrote:
>
>> As far as I can tell from the pubs, an involuntary conversion of stock
>> (i.e. a company buys out, via a tender offer, another company and then
>> forced shareholders that did not tender their shares to sell), is not
>> an involuntary conversion for tax purposes. Can somebody please tell
>> me that I am wrong.
>
> It's an involuntary conversion (Title 26, Subtitle A, Chapter 1,
> Subchapter O, Part III, Sectioh 1033), but since it's a conversion
> into similar property, under the General Rule it is not a
> tax event. Your basis and holding period are carried over
> to the new shares.
>
> Steve
>
I think he is saying that he did not tender his shares; the
company making the offer was successful; and his shares were
converted to cash. As such, it is treated no differently then any
other sale of stock.

--
<< ------------------------------------------------------- >>
<< The foregoing was not intended or written to be used, >>
<< nor can it used, for the purpose of avoiding penalties >>
<< that may be imposed upon the taxpayer. >>
<< >>
<< The Charter and the Guidelines for submitting posts >>
<< to this newsgroup as well as our anti-spamming policy >>
<< are at www.asktax.org. >>
<< Copyright (2007) - All rights reserved. >>
<< ------------------------------------------------------- >>

Posted by Steve Pope on August 4, 2009, 8:43 pm
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>Steve Pope wrote:


>>> As far as I can tell from the pubs, an involuntary conversion of stock
>>> (i.e. a company buys out, via a tender offer, another company and then
>>> forced shareholders that did not tender their shares to sell), is not
>>> an involuntary conversion for tax purposes. Can somebody please tell
>>> me that I am wrong.

>> It's an involuntary conversion (Title 26, Subtitle A, Chapter 1,
>> Subchapter O, Part III, Section 1033), but since it's a conversion
>> into similar property, under the General Rule it is not a
>> tax event. Your basis and holding period are carried over
>> to the new shares.

>I think he is saying that he did not tender his shares; the
>company making the offer was successful; and his shares were
>converted to cash. As such, it is treated no differently then any
>other sale of stock.

Oops. Right, I misinterpreted it as an exchange.

Steve

--
<< ------------------------------------------------------- >>
<< The foregoing was not intended or written to be used, >>
<< nor can it used, for the purpose of avoiding penalties >>
<< that may be imposed upon the taxpayer. >>
<< >>
<< The Charter and the Guidelines for submitting posts >>
<< to this newsgroup as well as our anti-spamming policy >>
<< are at www.asktax.org. >>
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Posted by DF2 on August 4, 2009, 10:50 pm
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In misc.taxes.moderated, Steve Pope wrote:

>
>>As far as I can tell from the pubs, an involuntary conversion of stock
>>(i.e. a company buys out, via a tender offer, another company and then
>>forced shareholders that did not tender their shares to sell), is not
>>an involuntary conversion for tax purposes. Can somebody please tell
>>me that I am wrong.

If you got cash only, it's a sell. If you got something else, then
it depends...


>
>It's an involuntary conversion (Title 26, Subtitle A, Chapter 1,
>Subchapter O, Part III, Sectioh 1033), but since it's a conversion
>into similar property, under the General Rule it is not a
>tax event. Your basis and holding period are carried over
>to the new shares.
>
>Steve

--
<< ------------------------------------------------------- >>
<< The foregoing was not intended or written to be used, >>
<< nor can it used, for the purpose of avoiding penalties >>
<< that may be imposed upon the taxpayer. >>
<< >>
<< The Charter and the Guidelines for submitting posts >>
<< to this newsgroup as well as our anti-spamming policy >>
<< are at www.asktax.org. >>
<< Copyright (2007) - All rights reserved. >>
<< ------------------------------------------------------- >>

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