Non-Applicability of Section 357(c) to Consolidated Groups
This document contains final regulations clarifying that, in the case of certain transfers between members of a consolidated group, a transferee's assumption of certain liabilities will not reduce the transferor's basis in the transferee's stock received in the transfer. These final regulations affect consolidated groups and their members.
This document contains final regulations clarifying that, in the case of certain transfers between members of a consolidated group, a transferee's assumption of certain liabilities will not reduce the transferor's basis in the transferee's stock received in the transfer. These final regulations affect consolidated groups and their members.
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Why it matters
The final regulations clarifying the non-applicability of Section 357(c) to consolidated groups represent a notable regulatory clarification affecting tax basis treatment within corporate groups, which may influence structuring and tax planning for consolidated groups but does not directly alter credit markets or lending conditions.
Sources
Federal Register
Non-Applicability of Section 357(c) to Consolidated Groups
This document contains final regulations clarifying that, in the case of certain transfers between members of a consolidated group, a transferee's assumption of certain liabilities will not reduce the transferor's basis in the transferee's stock received in the transfer. These final regulations affect consolidated groups and their members.