IRS issues helpful regs. on the interplay of active trade and hot stock.
The Tax Adviser › Vol. 40 Nbr. 4, April 2009
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IRS issues helpful regs. on the interplay of active trade and hot stock.
In response to changes made to the active trade or business requirement in the Tax Increase Prevention and Reconciliation Act of 2005, EL. 109-222 (TIPRA), the Service recently issued temporary and proposed regulations harmonizing the Sec. 355 "hot stock" rule with the TIPRA changes (T.D. 9435, REG-150670-07).
Background Under Sec. 355(a), a distributing corporation (D) may distribute th...See the full content of this document
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