Internal Revenue Service December 12, 2008 – Federal Register Recent Federal Regulation Documents

Creditor Continuity of Interest
Document Number: E8-29271
Type: Rule
Date: 2008-12-12
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains final regulations providing guidance regarding when and to what extent creditors of a corporation will be treated as proprietors of the corporation in determining whether continuity of interest (``COI'') is preserved in a potential reorganization. These final regulations are necessary to provide clarity to parties engaging in reorganizations of insolvent corporations, both inside and outside of bankruptcy. These final regulations affect corporations, their creditors, and their shareholders.