Same-taxpayer principle
Also called: same taxpayer rule · same entity rule
Industry shorthand for the need to maintain appropriate taxpayer continuity between the relinquished and replacement sides of an exchange.
What it means in practice.
The phrase is a planning shorthand, not a standalone statutory label. Changes involving LLCs, partnerships, trusts or co-owners should be evaluated for federal tax ownership and reporting consequences.
Why it matters.
Entity restructuring immediately before or after an exchange is a frequent professional-review issue.
Additional notes.
The phrase is a planning shorthand, not a standalone statutory label. Changes involving LLCs, partnerships, trusts or co-owners should be evaluated for federal tax ownership and reporting consequences.
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