You can’t spell “Subchapter C” without E&P: proposed Treasury regulations clarify the rules concerning the allocation of earnings and profits in tax-free transfers *

USA - April 17 2012
On April 13, 2012, Treasury and the Internal Revenue Service (the IRS) issued proposed regulations that aim to clarify the rule of Treas. Reg. § 1.312-11(a), which concerns the allocation of earnings and profits in tax-free transfers between corporations (the Proposed Regulations).

Co-authors: Reginald J. Clark , Robert S. Chase II, William E. Sheumaker, William R. Pauls.