SECTION 1. PURPOSE
Internal Revenue Bulletin 2016-32 · 2026-10-03 edition · updated 2026-10-04 · United States
This revenue procedure provides fact patterns (safe harbors) in which the Internal Revenue Service (IRS) will not assert that a distributing corporation, D, lacks control of another corporation, C, within the meaning of § 355(a)(1)(A) of the Internal Revenue Code (Code), even though D and C engage in a transaction described in sections 3 and 4 of this revenue procedure.
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