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Use of Controlled Corporations To Avoid the Application of Section 304

tax-irs · IRS · Rule · Published 2009-12-30 · Effective 2009-12-30 · 74 FR 69021

Document

Document number
E9-30861
Federal Register citation
74 FR 69021
CFR reference
26 CFR 1
Type
Rule
Action
Final and temporary regulations.
Category
tax-irs
Sub-agency
IRS
Publication date
2009-12-30
Effective date
2009-12-30
Treasury docket
TD 9477

Abstract

This document contains final and temporary regulations under section 304 of the Internal Revenue Code (Code). The regulations apply to certain transactions that are subject to section 304 but that are entered into with a principal purpose of avoiding the application of section 304 to a corporation that is controlled by the issuing corporation in the transaction, or with a principal purpose of avoiding the application of section 304 to a corporation that controls the acquiring corporation in the transaction. The regulations affect persons treated as receiving distributions in redemption of stock by reason of section 304. The text of the temporary regulations serves as the text of the proposed regulations in the notice of proposed rulemaking on this subject published in the Proposed Rules section of this issue of the Federal Register.

Source

Authoritative
Federal Register document
Machine
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