Regulacje i polityka gospodarcza · 22/11/2004

IRS Proposes Regulations on Predecessors and Successors Under Section 355(e) and Gain Recognition

The IRS has released proposed regulations that provide guidance on determining whether a corporation is a predecessor or successor of a distributing or controlled corporation, and rules to help taxpayers determine if an acquisition of an interest in a corporation would cause a distributing corporation to recognize gain under section 355(e). These regulations apply to corporations that distribute the stock of controlled corporations in distributions described in section 355.