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TREAS/IRS | RIN: 1545-BJ21 | Publication ID: Fall 2013 |
Title: Corporate Reorganizations; Allocation of Basis in Section 368(a)(1)(D) Reorganizations | |
Abstract: This document contains final regulations amending section 1.358-2, which provides guidance regarding the determination of the basis of stock or securities in a reorganization 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, in a reorganization described in section 368(a)(1)(D) where no stock and/or securities of the acquiring corporation is issued and distributed in the transaction, the ability to designate the share of stock of the acquiring corporation to which the basis, if any, of the stock or securities surrendered will attach applies only to a shareholder that owns actual shares in the acquiring corporation. | |
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: Undetermined |
CFR Citation: Not Yet Determined (To search for a specific CFR, visit the Code of Federal Regulations.) | |
Legal Authority: 26 USC 7805 26 USC 368 |
Legal Deadline:
None |
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Timetable:
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Additional Information: REG-101273-10 Drafting attorney: Amie Colwell Breslow (202) 622-5429 Reviewing attorney: Lawrence Axelrod (202) 622-7713 Treasury attorney: Kirshna P. Vallabhaneni (202) 622-0835 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: Lynlee Baker Attorney Department of the Treasury Internal Revenue Service 1111 Constitution Avenue NW., Room 5409, Washington, DC 20224 Phone:202 317-6937 Fax:202 317-4922 Email: lynlee.c.baker@irscounsel.treas.gov |