Code of Federal Regulations (Last Updated: November 8, 2024) |
Title 26 - Internal Revenue |
Chapter I - Internal Revenue Service, Department of the Treasury |
SubChapter A - Income Tax |
Part 1 - Income Taxes |
Special Rules for Determining Capital Gains and Losses |
§ 1.1248-1T - Treatment of gain from certain sales or exchanges of stock in certain foreign corporations (temporary).
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(a) [Reserved] For further guidance, see §1.1248–1(a).
(b) Sale or exchange . For purposes of section 1248(a), the term sale or exchange includes the receipt of a distribution which is treated as in exchange for stock under section 302(a) (relating to distributions in redemption of stock), section 331(a)(1) (relating to distributions in complete liquidation of a corporation), or section 331(a)(2) (relating to distributions in partial liquidation of a corporation). For purposes of section 1248(a), gain recognized by a shareholder under section 301(c)(3) in connection with a distribution of property by a corporation with respect to its stock shall be treated as gain from the sale or exchange of stock of such corporation.
(c) through (f) [Reserved] For further guidance, see §1.1248–1(c) through (f).
(g) Effective/applicability dates . (1) [Reserved] For further guidance, see §1.1248–1(g)(1).
(2) Paragraph (b) of this section applies to distributions that occur on or after February 10, 2009.
(h) Expiration date . This section expires on or before February 10, 2012.
[T.D. 9444, 74 FR 6828, Feb. 11, 2009]