SECTION 5. DISTRIBUTION OF
Internal Revenue Bulletin 2008-47 · 2026-10-03 edition · updated 2026-10-04 · United States
QUALIFIED PREFERRED STOCK BY CERTAIN PARTNERSHIPS TO A PARTNER THAT IS AN APPLICABLE FINANCIAL INSTITUTION
.01 Scope . This section applies if all of the following are satisfied:
(1) After September 6, 2008, a partner (the taxpayer) acquired QPS as a result of a distribution from a partnership (the Acquisition);
2008–47 I.R.B. 1197 November 24, 2008
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