Internal Revenue Service December 30, 2009 – Federal Register Recent Federal Regulation Documents

Use of Controlled Corporations To Avoid the Application of Section 304
Document Number: E9-30863
Type: Proposed Rule
Date: 2009-12-30
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
In the Rules and Regulations section of this issue of the Federal Register, the IRS and the Treasury Department are issuing temporary regulations under section 304 of the Internal Revenue Code (Code). The temporary regulations apply to certain transactions that are subject to section 304 but that are entered into with a principal purpose of avoiding the application of section 304 to a corporation controlled by the issuing corporation in the transaction, or to a corporation that controls the acquiring corporation in the transaction. The temporary regulations affect shareholders treated as receiving distributions in redemption of stock by reason of section 304. The text of temporary regulations published in this issue of the Federal Register serves as the text of these proposed regulations.
Use of Controlled Corporations To Avoid the Application of Section 304
Document Number: E9-30861
Type: Rule
Date: 2009-12-30
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains final and temporary regulations under section 304 of the Internal Revenue Code (Code). The regulations apply to certain transactions that are subject to section 304 but that are entered into with a principal purpose of avoiding the application of section 304 to a corporation that is controlled by the issuing corporation in the transaction, or with a principal purpose of avoiding the application of section 304 to a corporation that controls the acquiring corporation in the transaction. The regulations affect persons treated as receiving distributions in redemption of stock by reason of section 304. The text of the temporary regulations serves as the text of the proposed regulations in the notice of proposed rulemaking on this subject published in the Proposed Rules section of this issue of the Federal Register.