Indirect Stock Transfers and the Coordination Rule Expectation - Transfers of Stock Or Securities in Outbound Asset Reorganizations (Us Internal Revenue Service Regulation) (Irs) (2018 Edition) PDF Download

Author: The Law The Law Library
Publisher: Createspace Independent Publishing Platform
ISBN: 9781729710296
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Languages : en
Pages : 28

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Indirect Stock Transfers and the Coordination Rule Expectation - Transfers of Stock or Securities in Outbound Asset Reorganizations (US Internal Revenue Service Regulation) (IRS) (2018 Edition) The Law Library presents the complete text of the Indirect Stock Transfers and the Coordination Rule Expectation - Transfers of Stock or Securities in Outbound Asset Reorganizations (US Internal Revenue Service Regulation) (IRS) (2018 Edition). Updated as of May 29, 2018 This document contains final regulations under sections 367, 1248, and 6038B of the Internal Revenue Code (Code). These regulations finalize the elimination of one of two exceptions to the coordination rule between asset transfers and indirect stock transfers for certain outbound asset reorganizations. The regulations also finalize modifications to the exception to the coordination rule for section 351 exchanges so that it is consistent with the remaining asset reorganization exception. In addition, the regulations finalize modifications to the procedures for obtaining relief for failures to satisfy certain reporting requirements. Finally, the regulations finalize certain changes with respect to transfers of stock or securities by a domestic corporation to a foreign corporation in a section 361 exchange. These regulations primarily affect domestic corporations that transfer property to foreign corporations in certain outbound nonrecognition exchanges. This book contains: - The complete text of the Indirect Stock Transfers and the Coordination Rule Expectation - Transfers of Stock or Securities in Outbound Asset Reorganizations (US Internal Revenue Service Regulation) (IRS) (2018 Edition) - A table of contents with the page number of each section

Author: The Law The Law Library
Publisher: Createspace Independent Publishing Platform
ISBN: 9781729710272
Category :
Languages : en
Pages : 34

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Indirect Stock Transfers and Coordination Rule Exceptions - Transfers of Stockor Securities in Outbound Asset Reorganizations (US Internal Revenue Service Regulation) (IRS) (2018 Edition) The Law Library presents the complete text of the Indirect Stock Transfers and Coordination Rule Exceptions - Transfers of Stockor Securities in Outbound Asset Reorganizations (US Internal Revenue Service Regulation) (IRS) (2018 Edition). Updated as of May 29, 2018 This document contains final and temporary regulations. These regulations eliminate one of two exceptions to the coordination rule between asset transfers and indirect stock transfers for certain outbound asset reorganizations. The regulations also modify the third exception to the coordination rule for certain outbound exchanges so that this exception is consistent with the remaining asset reorganization exception. In addition, the regulations modify, in various contexts, procedures for obtaining reasonable cause relief. Finally, the regulations implement certain changes with respect to transfers of stock or securities by a domestic corporation to a foreign corporation in a section 361 exchange. The regulations primarily affect domestic corporations that transfer property to foreign corporations in certain outbound nonrecognition exchanges. The text of these temporary regulations serves as the text of the proposed regulations (REG-132702-10) published in the notice of proposed rulemaking on this subject in the Proposed Rules section of this issue of the Federal Register. This book contains: - The complete text of the Indirect Stock Transfers and Coordination Rule Exceptions - Transfers of Stockor Securities in Outbound Asset Reorganizations (US Internal Revenue Service Regulation) (IRS) (2018 Edition) - A table of contents with the page number of each section

Author: The Law The Law Library
Publisher: Createspace Independent Publishing Platform
ISBN: 9781729689165
Category :
Languages : en
Pages : 54

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Certain Transfers of Stock or Securities by U.S. Persons to Foreign Corporations (US Internal Revenue Service Regulation) (IRS) (2018 Edition) The Law Library presents the complete text of the Certain Transfers of Stock or Securities by U.S. Persons to Foreign Corporations (US Internal Revenue Service Regulation) (IRS) (2018 Edition). Updated as of May 29, 2018 This document contains final and temporary regulations under section 367(a) of the Internal Revenue Code (Code) regarding gain recognition agreements. The final regulations are necessary to update cross-references in the current regulations. The temporary regulations are necessary to respond to comments requested in Notice 2005-74. The regulations primarily affect U.S. persons that transfer stock or securities to foreign corporations or corporations engaged in transactions that affect existing gain recognition agreements. The text of these temporary regulations also serves as the text of the proposed regulations (REG-147144-06) set forth in the notice of proposed rulemaking on this subject published elsewhere in this issue of the Federal Register. This book contains: - The complete text of the Certain Transfers of Stock or Securities by U.S. Persons to Foreign Corporations (US Internal Revenue Service Regulation) (IRS) (2018 Edition) - A table of contents with the page number of each section

Author: The Law The Law Library
Publisher: Createspace Independent Publishing Platform
ISBN: 9781729689134
Category :
Languages : en
Pages : 70

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Certain Outbound Property Transfers by Domestic Corporations - Certain Stock Distributions by Domestic Corporations (US Internal Revenue Service Regulation) (IRS) (2018 Edition) The Law Library presents the complete text of the Certain Outbound Property Transfers by Domestic Corporations - Certain Stock Distributions by Domestic Corporations (US Internal Revenue Service Regulation) (IRS) (2018 Edition). Updated as of May 29, 2018 This document contains final and temporary regulations that apply to transfers of certain property by a domestic corporation to a foreign corporation in certain nonrecognition exchanges, or to distributions of stock of certain foreign corporations by a domestic corporation in certain nonrecognition distributions. The final regulations also establish reporting requirements for property transfers and stock distributions to which the final regulations apply. The regulations affect domestic corporations that transfer property to foreign corporations in certain nonrecognition transactions, or that distribute the stock of certain foreign corporations in certain nonrecognition distributions, and certain domestic shareholders of those domestic corporations. This book contains: - The complete text of the Certain Outbound Property Transfers by Domestic Corporations - Certain Stock Distributions by Domestic Corporations (US Internal Revenue Service Regulation) (IRS) (2018 Edition) - A table of contents with the page number of each section

Author: The Law The Law Library
Publisher: Createspace Independent Publishing Platform
ISBN: 9781729701263
Category :
Languages : en
Pages : 62

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Gain Recognition Agreements with Respect to Certain Transfers of Stock or Securities by United States Persons to Foreign Corporations (US Internal Revenue Service Regulation) (IRS) (2018 Edition) The Law Library presents the complete text of the Gain Recognition Agreements with Respect to Certain Transfers of Stock or Securities by United States Persons to Foreign Corporations (US Internal Revenue Service Regulation) (IRS) (2018 Edition). Updated as of May 29, 2018 This document contains final regulations under section 367(a) of the Internal Revenue Code (Code) concerning gain recognition agreements filed by United States persons with respect to transfers of stock or securities to foreign corporations. The regulations finalize temporary regulations published on February 5, 2007 (TD 9311). The regulations primarily affect United States persons that transfer (or have transferred) stock or securities to foreign corporations and that will enter (or have entered) into a gain recognition agreement with respect to such a transfer. This book contains: - The complete text of the Gain Recognition Agreements with Respect to Certain Transfers of Stock or Securities by United States Persons to Foreign Corporations (US Internal Revenue Service Regulation) (IRS) (2018 Edition) - A table of contents with the page number of each section

Author: The Law The Law Library
Publisher: Createspace Independent Publishing Platform
ISBN: 9781729735572
Category :
Languages : en
Pages : 124

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Unified Rule for Loss on Subsidiary Stock (US Internal Revenue Service Regulation) (IRS) (2018 Edition) The Law Library presents the complete text of the Unified Rule for Loss on Subsidiary Stock (US Internal Revenue Service Regulation) (IRS) (2018 Edition). Updated as of May 29, 2018 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. This book contains: - The complete text of the Unified Rule for Loss on Subsidiary Stock (US Internal Revenue Service Regulation) (IRS) (2018 Edition) - A table of contents with the page number of each section

Author: The Law The Law Library
Publisher: Createspace Independent Publishing Platform
ISBN: 9781729735466
Category :
Languages : en
Pages : 52

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Treatment of Certain Transfers of Property to Foreign Corporations (US Internal Revenue Service Regulation) (IRS) (2018 Edition) The Law Library presents the complete text of the Treatment of Certain Transfers of Property to Foreign Corporations (US Internal Revenue Service Regulation) (IRS) (2018 Edition). Updated as of May 29, 2018 This document contains final regulations relating to certain transfers of property by United States persons to foreign corporations. The final regulations affect United States persons that transfer certain property, including foreign goodwill and going concern value, to foreign corporations in nonrecognition transactions described in section 367 of the Internal Revenue Code (Code). The regulations also combine certain sections of the existing regulations under section 367(a) into a single section. This document also withdraws certain temporary regulations. This book contains: - The complete text of the Treatment of Certain Transfers of Property to Foreign Corporations (US Internal Revenue Service Regulation) (IRS) (2018 Edition) - A table of contents with the page number of each section

Author: The Law The Law Library
Publisher: Createspace Independent Publishing Platform
ISBN: 9781729691397
Category :
Languages : en
Pages : 34

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Determination of Basis of Stock or Securities Received in Exchange for, or With Respect to, Stock or Securities in Certain Transactions (US Internal Revenue Service Regulation) (IRS) (2018 Edition) The Law Library presents the complete text of the Determination of Basis of Stock or Securities Received in Exchange for, or With Respect to, Stock or Securities in Certain Transactions (US Internal Revenue Service Regulation) (IRS) (2018 Edition). Updated as of May 29, 2018 This document contains final regulations under section 358 that provide guidance regarding the determination of the basis of stock or securities received in exchange for, or with respect to, stock or securities in certain transactions. This document also contains temporary regulations under section 1502 that govern certain basis determinations and adjustments of subsidiary stock in certain transactions involving members of a consolidated group. The text of the temporary regulations also serves as the text of the proposed regulations set forth in the notice of proposed rulemaking on this subject in the Proposed Rules section in this issue of the Federal Register. The final and temporary regulations affect shareholders of corporations. This book contains: - The complete text of the Determination of Basis of Stock or Securities Received in Exchange for, or With Respect to, Stock or Securities in Certain Transactions (US Internal Revenue Service Regulation) (IRS) (2018 Edition) - A table of contents with the page number of each section

Author: The Law The Law Library
Publisher: Createspace Independent Publishing Platform
ISBN: 9781729704868
Category :
Languages : en
Pages : 26

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Guidance for Determining Stock Ownership (US Internal Revenue Service Regulation) (IRS) (2018 Edition) The Law Library presents the complete text of the Guidance for Determining Stock Ownership (US Internal Revenue Service Regulation) (IRS) (2018 Edition). Updated as of May 29, 2018 This document contains temporary regulations that identify certain stock of a foreign corporation that is disregarded in calculating ownership of the foreign corporation for purposes of determining whether it is a surrogate foreign corporation. These regulations also provide guidance with respect to the effect of transfers of stock of a foreign corporation after the foreign corporation has acquired substantially all of the properties of a domestic corporation or of a trade or business of a domestic partnership. These regulations affect certain domestic corporations and partnerships (and certain parties related thereto), and foreign corporations that acquire substantially all of the properties of such domestic corporations or of the trades or businesses of such domestic partnerships. The text of the temporary regulations serves as the text of the proposed regulations set forth in the Proposed Rules section in this issue of the Federal Register. This document also contains a final regulation that provides a cross-reference to the temporary regulations. This book contains: - The complete text of the Guidance for Determining Stock Ownership (US Internal Revenue Service Regulation) (IRS) (2018 Edition) - A table of contents with the page number of each section

Author: The Law The Law Library
Publisher: Createspace Independent Publishing Platform
ISBN: 9781729704714
Category :
Languages : en
Pages : 40

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Guidance Under Section 355(e) Regarding Predecessors, Successors, and Limitation on Gain Recognition - Guidance Under Section 355(f) (US Internal Revenue Service Regulation) (IRS) (2018 Edition) The Law Library presents the complete text of the Guidance Under Section 355(e) Regarding Predecessors, Successors, and Limitation on Gain Recognition - Guidance Under Section 355(f) (US Internal Revenue Service Regulation) (IRS) (2018 Edition). Updated as of May 29, 2018 This document contains temporary regulations that provide guidance regarding the distribution by a distributing corporation of stock or securities of a controlled corporation without the recognition of income, gain, or loss. The temporary regulations provide guidance in determining whether a corporation is a predecessor or successor of a distributing or controlled corporation for purposes of the exception under section 355(e) of the Internal Revenue Code (Code) to the nonrecognition treatment afforded qualifying distributions, and they provide certain limitations on the recognition of gain in certain cases involving a predecessor of a distributing corporation. The temporary regulations also provide rules regarding the extent to which section 355(f) of the Code causes a distributing corporation (and in certain cases its shareholders) to recognize income or gain on the distribution of stock or securities of a controlled corporation. These temporary regulations affect corporations that distribute the stock or securities of controlled corporations and the shareholders or security holders of those distributing corporations. The text of these temporary regulations also serves as the text of the proposed regulations in the related notice of proposed rulemaking (REG-140328-15) set forth in the Proposed Rules section in this issue of the Federal Register. This book contains: - The complete text of the Guidance Under Section 355(e) Regarding Predecessors, Successors, and Limitation on Gain Recognition - Guidance Under Section 355(f) (US Internal Revenue Service Regulation) (IRS) (2018 Edition) - A table of contents with the page number of each section