Use of Controlled Corporations To Avoid the Application of Section 304
other · IRS · Rule · Published 2012-12-26 · Effective 2012-12-26 · 77 FR 75844
Document
Document number
2012-30967
Federal Register citation
77 FR 75844
CFR reference
26 CFR 1
Type
Rule
Action
Final regulations and removal of temporary regulations.
Category
other
Sub-agency
IRS
Publication date
2012-12-26
Effective date
2012-12-26
Treasury docket
TD 9606
Abstract
This document contains final regulations addressing sales of stock between related corporations. The regulations finalize proposed regulations and remove temporary regulations that apply to certain sales of stock that are recharacterized as contributions and redemptions, but that are structured with a principal purpose of redesignating the issuing corporation or the acquiring corporation. The regulations affect persons treated as receiving distributions in redemption of stock as a result of such transactions.