The US Treasury Department and the Internal Revenue Service on Wednesday announced that proposed regulations had been issued regarding the circumstances in which an insolvent corporation may engage in a tax-free reorganization.
The regulations generally provide that a transaction can qualify as a tax-free asset reorganization only if the target corporation transfers property with net value to the acquiring corporation.
Similar rules for tax-free stock reorganizations, tax-free liquidations, and tax-free incorporations are also outlined in the new rules.
Comments are invited on the proposed regulations for a 90 day period following their publication in the federal register.
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