INCOME TAX

T.D. 9556, page 862. Final regulations under section 6011 of the Code provide rules requiring the disclosure of listed transactions and transactions of interest with respect to the generation-skipping transfer tax and make conforming amendments under sections 6111 and 6112. The regulations provide guidance under section 6112 regarding the length of time a material advisor has to prepare the list that must be maintained after the list maintenance requirement first arises with respect to the reportable transaction and clarify the provisions regarding designation agreements.

T.D. 9557, page 855. Final regulations under section 108 of the Code provide guidance in determining the discharge of indebtedness income of a partnership that transfers a partnership interest to a creditor in satisfaction of the partnership’s indebtedness, provide that section 721 generally applies to a contribution of a partnership’s indebtedness by a creditor to the partnership in exchange for an interest in the partnership, and provide guidance for how a partnership’s discharge of indebtedness income is allowed as a minimum gain chargeback under section 704.

T.D. 9558, page 859. REG–101273–10, page 873. Temporary regulations under section 358 of the Code clarify that, in certain reorganizations where no stock or securities of the issuing corporation is issued and distributed in the transaction, the ability to designate the share of stock of the issuing corporation to which the basis, if any, of the stock or securities surrendered will attach applies only to a shareholder that owns actual shares in the issuing corporation.

Finding Lists begin on page ii.