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document_number title type abstract publication_date pub_year pub_month html_url pdf_url agency_names agency_ids excerpts regulation_id_numbers
2013-05696 Indirect Stock Transfers and the Coordination Rule Exceptions; Transfers of Stock or Securities in Outbound Asset Reorganizations Rule This document contains final and temporary regulations. These regulations eliminate one of two exceptions to the coordination rule between asset transfers and indirect stock transfers for certain outbound asset reorganizations. The regulations also modify the third exception to the coordination rule for certain outbound exchanges so that this exception is consistent with the remaining asset reorganization exception. In addition, the regulations modify, in various contexts, procedures for obtaining reasonable cause relief. Finally, the regulations implement certain changes with respect to transfers of stock or securities by a domestic corporation to a foreign corporation in a section 361 exchange. The regulations primarily affect domestic corporations that transfer property to foreign corporations in certain outbound nonrecognition exchanges. The text of these temporary regulations serves as the text of the proposed regulations (REG-132702- 10) published in the notice of proposed rulemaking on this subject in the Proposed Rules section of this issue of the Federal Register. 2013-03-19 2013 3 https://www.federalregister.gov/documents/2013/03/19/2013-05696/indirect-stock-transfers-and-the-coordination-rule-exceptions-transfers-of-stock-or-securities-in https://www.govinfo.gov/content/pkg/FR-2013-03-19/pdf/2013-05696.pdf Treasury Department; Internal Revenue Service 497,254 This document contains final and temporary regulations. These regulations eliminate one of two exceptions to the coordination rule between asset transfers and indirect stock transfers for certain outbound asset reorganizations. The regulations also... 1545-BJ75

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