This advisory discusses Treasury regulations that allow certain sellers of stock to elect to treat certain sales and distributions of 80 percent of the vote and value of the stock (“qualified stock disposition”) of a domestic target corporation as if the old target sold its assets to a new target and liquidated into the stock seller. Treasury finalized the regulations to be effective for qualified stock dispositions with a disposition date on or after May 15, 2013. The disposition date is the date on which the qualifying amount of stock is disposed of over a period of 12 months or less, so this regulation is effective for transactions right now.
The advisory is provided on the Alston & Bird website: www.alston.com/advisories/fed-tax-aug-2013
Written by Jack Cummings, Partner, Tax | Alston & Bird LLP
