Prop. Treas. Reg. § 1.361-1 Nonrecognition of gain or loss to corporations.

Proposed 2014-12-23 · REG-109187-11 · 79 FR 76928 · Interprets § 361 · Would amend § 1.361-1

Par. 3. Section 1.361-1 is amended by adding new second and third sentences to read as follows:

* * * See § 1.453B-1(c) for rules requiring a corporation transferring an installment obligation to the acquiring corporation (as that term is used in § 1.368-1) to recognize gain or loss upon the receipt of stock of the acquiring corporation or another party to the reorganization (as defined in § 1.368-2(f)) in satisfaction of that installment obligation. The preceding sentence applies to satisfactions of installment obligations after the date these regulations are published as final regulations in the Federal Register .* * *