Study on Tax Rules for Complicated M & A Transactions including Corporate Reorganizations

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In recent years the Companies Act and Civil Code have been amended, and consequently the utilities of corporate reorganizations or M&A transactions, such as mergers, stock transfers, stock exchanges, corporate divisions and distributions in kinds, have increased. This study considered appropriate tax rules for such transactions under the neutrality and rationality point of view. Comparing the former rules with the new rules, Japanese rules with U.S. rules and through empirical research, it has become clear that there is still room for improving the current provisions.