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TREAS/IRS

RIN: 1545-BD84

Publication ID: Fall 2004

Title: ●Guidance Regarding Selected Issues Under Section 336(e)
Abstract: Proposed regulations will address the circumstances in which a corporation that owns stock in another corporation meeting the requirements of section 1504(a)(2) and that sells, exchanges, or distributes all of such stock, can make an election under section 336(e) to treat such sale, exchange, or distribution as a disposition of all the assets of such other corporation and recognize no gain or loss on the sale, exchange, or distribution of such stock.
Agency: Department of the Treasury(TREAS)	Priority: Substantive, Nonsignificant
RIN Status: First time published in the Unified Agenda	Agenda Stage of Rulemaking: Proposed Rule Stage
Major: Undetermined	Unfunded Mandates: Undetermined
CFR Citation: 26 CFR 1
Legal Authority: 26 USC 336    26 USC 7805

Legal Deadline:  None

Timetable: Action Date FR Cite NPRM  07/00/2005

Additional Information: REG-143544-04 Drafting attorney: Emidio J. Forlini (202) 622-7930 CC: CORP
Regulatory Flexibility Analysis Required: No	Government Levels Affected: None
Small Entities Affected: No	Federalism: No
Included in the Regulatory Plan: No
Agency Contact: Emidio J. Forlini Jr. Attorney Department of the Treasury Internal Revenue Service 1111 Constitution Avenue NW., Washington, DC 20224 Phone:202 622-7930