Reconstitution of the Specified Entity: changes in partner/member composition or shareholding that preserve continuity trigger tax treatment. Reconstitution of the Specified Entity is any change in a specified entity's composition or shareholding that preserves continuity of one or more pre change partners or members. It includes: cessation of one or more partners or members; admission of new partners or members where one or more pre change partners or members continue; and continuation of all partners or members with changes in their respective shares or in the shares of some members.
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Provisions expressly mentioned in the judgment/order text.
Reconstitution of the Specified Entity: changes in partner/member composition or shareholding that preserve continuity trigger tax treatment.
Reconstitution of the Specified Entity is any change in a specified entity's composition or shareholding that preserves continuity of one or more pre change partners or members. It includes: cessation of one or more partners or members; admission of new partners or members where one or more pre change partners or members continue; and continuation of all partners or members with changes in their respective shares or in the shares of some members.
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