Section 28 Formation of a Subsidiary

• Library: Business Transitions 2009 Supp

The American Jobs Creation Act of 2004, Pub. L. No. 108-357, 118 Stat. 1418, amended I.R.C. § 362 to prevent the possible duplication of losses by providing that, in the case of a transfer of built-in loss property in an I.R.C. § 351 transaction, the carryover basis will be reduced to the property’s fair market value immediately after the transfer. Section...