consistency period

(4) Consistency period (A) In general Except as provided in subparagraph (B), the term “consistency period” means the period consisting of— (i) the 1-year period before the beginning of the 12-month acquisition period for the target corporation, (ii) such acquisition period (up to and including the acquisition date), and (iii) the 1-year period beginning on the day after the acquisition date. (B) Extension where there is plan The period referred to in subparagraph (A) shall also include any period during which the Secretary determines that there was in effect a plan to make a qualified stock purchase plus 1 or more other qualified stock purchases (or asset acquisitions described in subsection (e)) with respect to the target corporation or any target affiliate.


26 USC § 338(h)(4)

Scoping language

For purposes of this section
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