Predecessor and Successor Regulations

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In December, the Treasury published temporary and proposed regulations clarifying the application of Section 355(e) when the distributing (D) corporation or the controlled (C) corporation has a predecessor (P) or successor (S). Section 355(e)(4)(D) states that references to D and C shall include a reference to P and S of such corporations. It purports to be effective without regulations. But practitioners have raised many questions about the meaning of this rule.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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