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TREAS/IRS | RIN: 1545-BH86 | Publication ID: Spring 2022 |
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 corporation's 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 corporation's attributes are reduced by the target corporation's attribute reduction amount. |
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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 |
CFR Citation: Not Yet Determined (To search for a specific CFR, visit the Code of Federal Regulations.) | |
Legal Authority: 26 U.S.C. 7805 |
Legal Deadline:
None |
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Timetable:
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Additional Information: REG-116446-08 (NPRM) Drafter attorney: Justin O. Kellar (202) 317-6847 Reviewer attorney: Julie Wang (202) 317-6975 Treasury attorney: Colin Campbell (202) 622-2297 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: Justin O. Kellar Senior Technician Reviewer Department of the Treasury Internal Revenue Service 1111 Constitution Avenue NW., Room 5140, Washington, DC 20224 Phone:202 317-6720 Fax:855 524-2088 Email: justin.o.kellar@irscounsel.treas.gov |