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Article Title

The Meaning of "Active Business" for Purposes of Divisive Reorganizations

Abstract

The requirement of an “active business” is a key requirement for a successful, tax-free corporate reorganization. 1 A distribution in conjunction with a reorganization must be motivated, in whole or substantial part, by one or more corporate business purposes. 2 For farm and ranch reorganizations, the business purpose requirement is a central feature of a divisive reorganization.

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