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U.S. Final Regulations Including Guidance Regarding Predecessors, Successors, and Limitation on Gain Recognition

23 December 2019

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Approved Changes

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United States

Final regulations (TD 9888) issued by the U.S. IRS and Treasury regarding predecessors, successors, and limitation on gain recognition were published in the Federal Register on 18 December 2019. The final regulations are effective on 16 December 2019. --- SUMMARY: This document contains final regulations that provide guidance regarding the distribution by a distributing corporation of stock or securities of a controlled corporation without the recognition of income, gain, or loss. In particular, the final regulations provide guidance in determining whether a corporation is a predecessor or successor of a distributing or controlled corporation for purposes of the exception under...