Tax consequences of CVR paid in cash

[kommonsents]

There has been some  discussion of the tax consequences of the CVR baing paid in cash at some point in the future.

Seems to me that any cash component we might receive in the future, over and above any OSH stoock we might receive, will simply reduce our cost basis on a per share basis, a return of capital, and only taxable on any amounts received over and above our cost basis on a per share basis.

Am I missing something here?

[katytrader]

There has been some  discussion of the tax consequences of the CVR baing paid in cash at some point in the future.

Seems to me that any cash component we might receive in the future, over and above any OSH stoock we might receive, will simply reduce our cost basis on a per share basis, a return of capital, and only taxable on any amounts received over and above our cost basis on a per share basis.

Am I missing something here?

  IRS logic, perhaps.  See Roger Ritt's Boston Tax Forum paper.  Google Ritt CVR