By David E. Kahen
, Elliot Pisem
The courts have taken varying approaches to determining the basis of stock that is received by an insurance policyholder in exchange for the policyholder's surrender of membership rights in a mutual insurance company, in a "demutualization" transaction.
By Michael Miller
, Libin Zhang
Income tax treaties are designed, among other things, to prevent (or at least reduce) double taxation by allocating taxing jurisdiction between the two countries.