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Reorganization Rules Proposed

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The IRS issued proposed regulations to simplify and clarify rules governing accounting methods to be used after corporate reorganizations and tax-free liquidations under IRC section 381(a).


The proposed amendments to Treas. Reg. §§ 1.381(c)(4)-1 and 1.381(c)(5)-1 are intended to provide greater consistency between the corresponding Code paragraphs. They provide that the accounting method of an acquiring corporation after a § 381(a) transaction generally will depend on whether the trades or businesses of the parties to the transaction are combined. Comments on REG-151884-03 are requested by Feb. 14.