United States Government Publishing Office publisher pbl distributor dst United States National Archives and Records Administration Office of the Federal Register author aut Government Organization text government publication eng FR Regulatory Information 2025_register executive 2025-01-16 article Part VII Proposed Rules D09002ee1cf47b98d D09002ee1cf47bb10 United States Department of the Treasury originator org United States Government Agency or Subagency United States Internal Revenue Service originator org United States Government Agency or Subagency 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. 90 FR 5220 https://www.govinfo.gov/app/details/FR-2025-01-16/2025-00321 2025-00321 fr16ja25-51 RIN 1545-BR32 4830-01-P REG-112261-24 https://www.govinfo.gov/app/details/FR-2025-01-16/2025-00321 https://www.govinfo.gov/content/pkg/FR-2025-01-16/html/2025-00321.htm https://www.govinfo.gov/content/pkg/FR-2025-01-16/pdf/2025-00321.pdf Income Taxes Reporting and Recordkeeping Requirements 76 p. 5220 5295 90 FR 5220 Title 26 Part 1 26 CFR Part 1 RIN 1545-BR32 Guidance Regarding Certain Matters Relating to Nonrecognition of Gain or Loss in Corporate Separations, Incorporations, and Reorganizations; Federal Register Vol. 90, Issue PRORULE 2025-00321 VII DEPARTMENT OF THE TREASURY Internal Revenue Service 2025-03-17 REG-112261-24 4830-01-P 2025-00321 Notice of proposed rulemaking.

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.

Written or electronic comments and requests for a public hearing must be received by March 17, 2025. Concerning the proposed regulations, Justin R. Du Mouchel at (202) 317-6975 (not a toll-free number); concerning submissions of comments and requests for a hearing, contact the Publications and Regulations branch at (202) 317-6901 (not a toll- free number) or by email to publichearings@irs.gov (preferred). Income Taxes Reporting and Recordkeeping Requirements Nonrecognition of Gain or Loss in Corporate Separations, Incorporations, and Reorganizations, publichearings@irs.gov https://www.irs.gov https://www.regulations.gov Vol. 90, no. 10 Office of the Federal Register, National Archives and Records Administration 2025-01-16 continuing daily deposited born digital 888 p. Table of Contents: AE 2.7: GS 4.107: AE 2.106: KF70.A2 https://www.govinfo.gov/app/details/FR-2025-01-16 P0b002ee1cf476bf3 0097-6326 0042-1219 0364-1406 769-004-00000-9 000582072 f:fr16ja25 https://www.govinfo.gov/app/details/FR-2025-01-16 https://www.govinfo.gov/content/pkg/FR-2025-01-16/pdf/FR-2025-01-16.pdf https://www.govinfo.gov/content/pkg/FR-2025-01-16/xml/FR-2025-01-16.xml fdlp 4585 5467 DGPO 2025-01-16 2025-01-16 FR-2025-01-16 machine generated eng FR FR-2025-01-16 90 10