Today, the IRS and Treasury issued final regulations addressing the allocation of stock basis in an all cash D reorganization.  The final regulations amend regulations under Section 358(a) that provide rules for determining a taxpayer’s basis in stock or securities of an issuing corporation received without the recognition of gain or loss, as well as rules relating to the basis of other property received in the reorganization, in certain reorganizations described in Section 368.  These final regulations adopt without substantive change temporary regulations published on November 21, 2011.