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TREAS/IRS RIN: 1545-BO26 Publication ID: Spring 2025 
Title: Regulations Under Section 336(e) to Revise the Treatment of Certain Stock Dispositions as Asset Sales 
Abstract:

Proposed regulations under section 336(e) to revise the treatment of certain stock dispositions which are treated as asset sales. The proposed regulations would clarify how to make an election to treat certain sales, exchanges, and distributions of another corporation's stock as taxable sales of that corporation's assets, as well as make other clarifications. The proposed regulations will affect corporations and their shareholders.

 
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: No 
EO 14192 Designation: Other 
CFR Citation: 26 CFR 336   
Legal Authority: IRC sec. 336(e)    IRC sec. 7805    IRC sec. 1502   
Legal Deadline:  None
Timetable:
Action Date FR Cite
NPRM  05/00/2026 
Additional Information: REG-129058-14 (NPRM) Drafter attorney: Mark Weiss (202) 317-6975 Reviewer attorney: N/A Treasury attorney: Colin Campbell (202) 622-2297; Theron West Jr. 202-622-5975 CC:CORP
Regulatory Flexibility Analysis Required: No  Government Levels Affected: None 
Small Entities Affected: Businesses  Federalism: No 
Included in the Regulatory Plan: No 
RIN Data Printed in the FR: No 
Agency Contact:
Mark Weiss
Branch Chief
Department of the Treasury
Internal Revenue Service
1111 Constitution Avenue NW., Room 5140,
Washington, DC 20224
Phone:202 317-6975
Fax:855 561-0922
Email: mark.weiss@irscounsel.treas.gov