INCOME TAX

T.D. 8960, page 176. Temporary regulations under section 355(e) of the Code generally require corporations to recognize gain on certain distributions of stock or securities of a subsidiary corporation if the distribution is part of a plan that also involves one or more persons acquiring a 50-percent or greater interest in the distributing corporation or any controlled corporation.

Rev. Proc. 2001–43, page 191. Partnership profits interests. This procedure clarifies Rev. Proc. 93–27 (1993–2 C.B. 343) by providing guidance on the treatment of the grant of a partnership profits interest that is substantially nonvested for the provision of services to or for the benefit of the partnership. Rev. Proc. 93–27 clarified.