Internal Revenue Bulletin: 2009-8 |
February 23, 2009 |
Table of Contents
- Highlights of This Issue
- Preface
- Part I. Rulings and Decisions Under the Internal Revenue Code of 1986
- Part II. Treaties and Tax Legislation
- Part III. Administrative, Procedural, and Miscellaneous
- Part IV. Items of General Interest
- REG-143686-07
- AGENCY:
- ACTION:
- SUMMARY:
- DATES:
- ADDRESSES:
- FOR FURTHER INFORMATION CONTACT:
- SUPPLEMENTARY INFORMATION:
- Background
- Explanation of Provisions
- I. Introduction — Exchanges and Distributions to Which Sections 301 and 302 Apply
- II. Distributions with Respect to Stock and Dividend Equivalent Transactions
- A. Section 301 distributions
- B. Dividend equivalent redemptions
- i. Basis adjustments in dividend equivalent redemptions if less than all of the shares of a single class held by the taxpayer are redeemed
- ii Basis recovery in dividend equivalent redemptions in which the taxpayer surrenders all of its shares in a single class
- C. Dividend equivalent reorganization exchanges
- D. Special rules related to apportionment of interest and other expenses
- E. Section 1059
- F. Redemptions of stock held by partnerships, trusts, and S corporations
- G. Consolidated groups and basis recovery in dividend equivalent redemptions
- III. Redemptions Treated as a Sale or Exchange Pursuant to Section 302(a)
- A. In general
- B. Reorganization exchanges that result in sale or exchange treatment
- IV. Extension of Tracing Principles to Determine Basis in Certain stock Transfers that are Not Reorganizations, and Other Proposals in Response to Specific Comments
- A. Application of tracing principles to certain section 351 exchanges and capital
- B. Miscellaneous
- V. Specifically Requested Comments
- Special Analyses
- Comments and Public Hearing
- Availability of IRS Documents
- Proposed Amendments to the Regulations
- Drafting Information
- Announcement 2009-4
- Announcement of Disciplinary Sanctions From the Office of Professional Responsibility
- REG-143686-07
- Definition of Terms and Abbreviations
- Numerical Finding List
- Effect of Current Actions on Previously Published Items
- How to get the Internal Revenue Bulletin
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