WebDec 3, 2007 · These proposed regulations clarify and simplify the existing regulations under sections 381(c)(4) and (c)(5). The regulations affect corporations that acquire the assets … WebExample 2.X Corporation acquired all the assets of Z Corporation solely in exchange for voting stock of X Corporation in a transaction qualifying under section 368(a)(1)(C). Thereafter, pursuant to the plan of reorganization X Corporation transferred all the assets so acquired to Y Corporation, its wholly-owned subsidiary (see section 368(a)(2 ...
Sec. 1.381(c)(4)-1 Method of accounting. - taxnotes.com
Webprovided in paragraphs (c) and (d) of this section. Where such change is a change from the accrual to the install-ment method by a dealer in personal property, section 453(c) and the … WebAug 8, 2006 · 4 These final regulations address the portions of the 200 0 proposed regulations (Prop. Reg.) dealing with inbound nonrecognition transactions ( Prop. Reg. §1.367(b) -3) and foreign section 381 transactions (Prop. R eg. §1.367 (b)-7). They also address the special rules of Prop. R eg. §1.367 -9. rms sharing application for windows
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WebTitle 26 was last amended 11/30/2024. view historical versions. Title 26. Chapter I. Subchapter A. Part 1. Carryovers. § 1.381 (d)-1. Previous. WebSep 14, 2024 · On December 28, 2024, the Department of the Treasury (Treasury Department) and the IRS (1) published proposed regulations under section 163(j), as amended by the TCJA, in a notice of proposed rulemaking (REG-106089-18) (2024 Proposed Regulations) in the Federal Register (83 FR 67490), and (2) withdrew the notice of … WebApr 1, 2001 · Under Sec. 381(c)(1)(B), the acquiring corporation (Acquiring) in a tax-free asset reorganization may use the target corporation's (Target's) net operating loss … rms shape codes