Continuity of Interest in Transfer of Target Assets
After Qualified Stock Purchase of Target

[4830-01-u] DEPARTMENT OF THE TREASURY Internal Revenue Service 26 CFR Part 1 [TD 8626] RIN 1545-AT15

TITLE: Continuity of Interest in Transfer of Target Assets After Qualified Stock Purchase of Target

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Final regulations.

SUMMARY: This document prescribes final regulations under section 338 of the Internal Revenue Code regarding the transfer of target assets to the purchasing corporation or another member of the same affiliated group as the purchasing corporation after a qualified stock purchase (QSP) of target stock, if a section 338 election is not made. These regulations provide guidance to parties to such transfers.

DATES: These regulations are effective October 27, 1995. These regulations are applicable to transfers of target assets that occur on or after October 26, 1995.

FOR FURTHER INFORMATION CONTACT: Steven M. Flanagan at (202) 622-7790 (not a toll-free number).

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