Laws, Regulations & Annotations
Business Taxes Law Guide – Revision 2014
Sales and Use Tax Annotations
395.0000 OCCASIONAL SALES—SALE OF A BUSINESS—BUSINESS REORGANIZATION—Regulation 1595
(h) OWNERSHIP "SUBSTANTIALLY SIMILAR"—"REAL OR ULTIMATE" OWNERSHIP
395.1640 Percentage of Ownership. For the ownership of property before and after a transfer to be "substantially similar," as provided in section 6006.5(b) relating to occasional sales, the owners of the property after the transfer must have a percentage of ownership similar to their original interest. Thus, when majority shareholders in a small corporation exchange the corporate property for shares in a large corporation which held the remainder of the small corporation's stock, their percentage of ownership is materially reduced and, accordingly, their ownership is not "substantially similar" before and after the transfer. 4/24/59.