Modification to Consolidated Return Regulation Permitting an Election To Treat a Liquidation of a Target, Followed by a Recontribution to a New Target, as a Cross-Chain Reorganization
Final regulations and removal of temporary regulations.
Category
tax-irs
Sub-agency
IRS
Publication date
2012-06-20
Effective date
2012-06-20
Treasury docket
TD 9594
Abstract
This document contains final regulations under section 1502 of the Internal Revenue Code (Code). These final regulations modify the election under which a consolidated group can avoid immediately taking into account an intercompany item after the liquidation of a target corporation. These regulations apply to corporations filing consolidated income tax returns.