Internal Revenue Service March 10, 2005 – Federal Register Recent Federal Regulation Documents

Transactions Involving the Transfer of No Net Value
Document Number: 05-4384
Type: Proposed Rule
Date: 2005-03-10
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains proposed regulations providing guidance regarding corporate formations, reorganizations, and liquidations of insolvent corporations. These regulations provide rules requiring the exchange (or, in the case of section 332, a distribution) of net value for the nonrecognition rules of subchapter C to apply to the transaction. The regulations also provide guidance on determining when and to what extent creditors of a corporation will be treated as proprietors of the corporation in determining whether continuity of interest is preserved in a potential reorganization. Finally, the regulations provide guidance on whether a distribution in cancellation or redemption of less than all of the shares one corporation owns in another corporation satisfies the requirements of section 332. The proposed regulations affect corporations and their shareholders.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.