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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
E7-3533 Corporate Reorganizations; Additional Guidance on Distributions Under Sections 368(a)(1)(D) and 354(b)(1)(B) Proposed Rule In the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing temporary regulations that amend Sec. 1.368-2T(l), which provides guidance regarding the qualification of certain transactions as reorganizations described in section 368(a)(1)(D) where no stock and/or securities of the acquiring corporation are issued and distributed in the transaction. These regulations clarify that the rules in Sec. 1.368-2T(l) are not intended to affect the qualification of related party triangular asset acquisitions as reorganizations described in section 368. These regulations affect corporations engaging in such transactions and their shareholders. The text of those regulations also serves as the text of these proposed regulations. 2007-03-01 2007 3 https://www.federalregister.gov/documents/2007/03/01/E7-3533/corporate-reorganizations-additional-guidance-on-distributions-under-sections-368a1d-and-354b1b https://www.govinfo.gov/content/pkg/FR-2007-03-01/pdf/E7-3533.pdf Treasury Department; Internal Revenue Service 497,254 In the Rules and Regulations section of this issue of the Federal Register, the IRS is issuing temporary regulations that amend Sec. 1.368-2T(l), which provides guidance regarding the qualification of certain transactions as reorganizations described...  

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