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TREAS/IRS | RIN: 1545-BG28 | Publication ID: Fall 2008 |
Title: Corporate Reorganizations; Additional Guidance on Distributions Under Sections 368(a)(1)(D) and 354(b)(1)(B) | |
Abstract: The IRS is issuing temporary regulations amending TD 9303, which provides guidance regarding the qualification of certain transactions as reorganizations described in section 368(a)(1)(D) where no stock and/or securities of the acquiring corporation are issued and distributed in the transaction. These regulations clarify that the rules in section 1.368-2(l) are not intended to affect the qualification of related party triangular asset acquisitions as reorganizations described in section 368 relating to the distribution requirement under sections 368(a)(1)(D) and 354(b)(1)(B). | |
Agency: Department of the Treasury(TREAS) | Priority: Substantive, Nonsignificant |
RIN Status: Previously published in the Unified Agenda | Agenda Stage of Rulemaking: Final Rule Stage |
Major: No | Unfunded Mandates: No |
CFR Citation: Not Yet Determined (To search for a specific CFR, visit the Code of Federal Regulations.) | |
Legal Authority: 26 USC 7805 |
Legal Deadline:
None |
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Timetable:
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Additional Information: REG-157834-06 Drafting attorney: Bruce A. Decker (202) 622-8039 Reviewing attorney: Lisa A. Fuller (202) 622-7152 Treasury attorney: Marc Countryman (202) 622-9858 CC: CORP | |
Regulatory Flexibility Analysis Required: No | Government Levels Affected: None |
Federalism: No | |
Included in the Regulatory Plan: No | |
RIN Data Printed in the FR: No | |
Related RINs: Related to 1545-BG29 | |
Agency Contact: Bruce A. Decker Senior Technician Reviewer Department of the Treasury Internal Revenue Service 1111 Constitution Avenue, NW, Room 5038, Washington, DC 20224 Phone:202 622-7930 Fax:202 622-6298 Email: bruce.a.decker@irscounsel.treas.gov |