This document contains final
regulations under sections 358, 362(e)(2), and 1502 of the Internal
Revenue Code (Code). The regulations apply to corporations filing
consolidated returns, and corporations that enter into certain
tax-free reorganizations. The regulations provide rules for
determining the tax consequences of a member's transfer (including
by deconsolidation and worthlessness) of loss shares of subsidiary
stock. In addition, the regulations provide that section 362(e)(2)
generally does not apply to transactions between members of a
consolidated group. Finally, the regulations conform or clarify
various provisions of the consolidated return regulations,
including those relating to adjustments to subsidiary stock
basis.
US Code:
26
USC 337(d) Name of Law: Nonrecognition for property distributed
to parent in complete liquidation of subsidiary
US Code: 26
USC 7805 Name of Law: Rules and regulations
US Code: 26
USC 1502 Name of Law: Regulations
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the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
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the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
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