U.S. Department of the Treasury

(Archived Content)

JS-2301

Today the Treasury Department and the Internal Revenue Service issued proposed regulations regarding the circumstances in which an insolvent corporation may engage in a tax-free reorganization.  The proposed 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.  The proposed regulations also provide similar rules for tax-free stock reorganizations, tax-free liquidations, and tax-free incorporations.

REPORTS

• The text of the regulations