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You Can't Spell "Subchapter C" Without E&P: Proposed Treasury Regulations Clarify The Rules Concerning The Allocation Of Earnings And Profits In Tax-Free Transfers

2012

Bloomberg BNA Tax and Accounting Center

Some practitioners have concluded that earnings and profits of an acquired corporation may be allocated between multiple corporations following a reorganization and a related contribution of less than all of the acquired corporation's assets. On April 13, 2012, Treasury and the Internal Revenue Service issued proposed regulations that aim to clarify the rule of Treas. Reg. § 1.312-11(a), which concerns the allocation of earnings and profits in tax-free transfers between corporations (the Proposed Regulations).

Robert S. Chase, II, Reginald J. Clark, Michael R. Miles, William R. Pauls, Aaron M. Payne and William E. Sheumaker – all attorneys in Sutherland’s Tax Practice Group – co-authored a piece on the topic, which was published by Bloomberg BNA Tax and Accounting Center.

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