The Meaning of "Active Business" for Purposes of Divisive Reorganizations
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.
Harl, Neil E.
"The Meaning of "Active Business" for Purposes of Divisive Reorganizations,"
Agricultural Law Digest: Vol. 15
, Article 1.
Available at: https://lib.dr.iastate.edu/aglawdigest/vol15/iss15/1