View Rule
View EO 12866 Meetings | Printer-Friendly Version Download RIN Data in XML |
TREAS/IRS | RIN: 1545-BH86 | Publication ID: Spring 2009 |
Title: Attribute Reduction Following Reorganizations | |
Abstract: The proposed regulations contain guidance concerning the treatment of attributes in reorganizations under section 368(a)(1), where the acquiring corporation is a shareholder in the target corporation, the target corporation terminates its existence, is able to make a distribution on only one class of its stock, and the acquiring corporation succeeds to the target corporations attributes under section 381 while the shareholder whose stock is eliminated for no consideration claims a loss. The proposed regulations provide that, to the extent such loss is duplicated in the attributes of the target corporation following its termination, the target corporations attributes are reduced by the target corporations attribute reduction amount. | |
Agency: Department of the Treasury(TREAS) | Priority: Substantive, Nonsignificant |
RIN Status: Previously published in the Unified Agenda | Agenda Stage of Rulemaking: Proposed Rule Stage |
Major: No | Unfunded Mandates: Undetermined |
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 |
||||||
Timetable:
|
Additional Information: REG-116446-08 Drafting attorney: Bruce A. Decker (202) 622-8039 Reviewing attorney: Lisa A. Fuller (202) 622-7750 Treasury attorney: Donald Bakke (202) 622-0865 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 | |
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 |