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TREAS/IRS RIN: 1545-BO26 Publication ID: Spring 2024 
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 
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  12/00/2024 
Additional Information: REG-129058-14 (NPRM) Drafter attorney: Samuel Trammell (202) 317-5024 Reviewer attorney: Mark Weiss (202) 317-5059 Treasury attorney: Colin Campbell (202) 622-2297 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:
Samuel G. Trammell
Senior Counsel
Department of the Treasury
Internal Revenue Service
1111 Constitution Avenue NW, Room 5428,
Washington, DC 20224
Phone:202 317-5939
Fax:855 561-0924
Email: samuel.g.trammell@irscounsel.treas.gov