Finance & markets · 21/12/1995

IRS Issues Final Regulations for Controlling Corporation Basis Adjustment in Stock Following Triangular Reorganization

The Internal Revenue Service (IRS) has released final regulations under sections 358, 1032, and 1502 of the Internal Revenue Code of 1986, outlining rules for adjusting the basis of a controlling corporation in the stock of a controlled corporation following a triangular reorganization, and treating the use of the controlling corporation's stock as a disposition of those shares.