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Data / Federal rules / 2025-00321

Guidance Regarding Certain Matters Relating to Nonrecognition of Gain or Loss in Corporate Separations, Incorporations, and Reorganizations

The Internal Revenue Service published this proposed rule in the Federal Register on January 16, 2025.

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What the agency says

This document contains proposed regulations regarding certain matters relating to corporate separations, incorporations, and reorganizations qualifying, in whole or in part, for nonrecognition of gain or loss. These matters include distributions and retentions of controlled corporation stock, assumptions of liabilities by controlled corporations, exchanges of property between distributing corporations and controlled corporations, and distributions and transfers of consideration to distributing corporation shareholders and creditors. The proposed regulations would affect corporations and their shareholders and security holders. Proposed regulations modifying the reporting requirements for corporate separations are published elsewhere in the Proposed Rules section of this issue of the Federal Register.

Key facts

Document number
2025-00321
Type
Proposed rule
Action
Notice of proposed rulemaking
Agency
Treasury Department; Internal Revenue Service
Published
January 16, 2025
Dates
Written or electronic comments and requests for a public hearing must be received by March 17, 2025.
Docket
REG-112261-24
Regulation ID (RIN)
1545-BR32
Code of Federal Regulations
26 CFR 1
Topics
Income taxes; Reporting and recordkeeping requirements
Pages
76

The document on federalregister.gov PDF

Other documents from the Internal Revenue Service

Everything from the Internal Revenue Service · Rules on income taxes · Rules on reporting and recordkeeping requirements · Published in January 2025

Read from the Federal Register API, last updated 2026-10-23. The document on federalregister.gov is the official record; dates and dockets can change through later corrections. Free to reuse with credit to SpecStream under CC BY 4.0.