Final regulations have been released that cover corporate predecessors, successors and taxable spin-offs. When certain requirements are met, a corporation may make a tax-free distribution of stock, or stock and securities, of a controlled corporation to the corporation’s shareholders, or to its shareholders and security holders. The IRS’s final regs provide guidance for determining whether a corporation is a predecessor or successor of a distributing or controlled corporation for purposes of the exception under U.S. tax code to the nonrecognition treatment afforded qualifying distributions. The final regs (http://bit.ly/2Z2pgK9 ) took effect on Dec.16, and apply to distributions after Dec.15.

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