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April 2004 Plain Language Regulations

Stock Basis in a Group Structure Change
These regulations provide rules for determining consolidated group members' basis in the stock of the common parent of the consolidated group following a transaction in which the common parent's stock is acquired by another corporation and the consolidated group remains in existence (a group structure change). The regulations have required the consolidated group members' basis in the stock of the former common parent to be determined with reference to the former common parent's net asset basis in both taxable and tax-free group structure changes. TD 9122.  Published April 26, 2004. 
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Partnership Allocations of Foreign Tax Expenditures
Partners are generally permitted to decide among themselves how a partnership's items (such as income and expenses) will be allocated, so long as such allocation has substantial economic effect, or is in accordance with the partners' interests in the partnership.  These regulations explain that the allocation of foreign tax expenditures lacks substantial economic effect and must be made in accordance with the partners' interests in the partnership.  These regulations provide a safe harbor where certain allocations of foreign tax expenditures will be deemed to be in accordance with the partner's interests in the partnership.  TD 9121.  Published April 21, 2004.
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Partnership Allocations of Foreign Tax Expenditures
Partners are generally permitted to decide among themselves how a partnership's items (such as income and expenses) will be allocated, so long as such allocation has substantial economic effect, or is in accordance with the partners' interests in the partnership.  These regulations explain that the allocation of foreign tax expenditures lacks substantial economic effect and must be made in accordance with the partners' interests in the partnership.  These regulations provide a safe harbor where certain allocations of foreign tax expenditures will be deemed to be in accordance with the partners' interests in the partnership.  REG-139792-02.  Published April 21, 2004.
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Modification of Check the Box
Some uncertainty exists regarding the assessment and collection of federal tax liabilities arising out of taxable periods during which a disregarded entity or an entity that merges into a disregarded entity is regarded.  These regulations clarify that an entity that is disregarded as separate from its owner, a qualified REIT subsidiary, and a qualified subchapter S subsidiary is treated as an entity separate from its owner if the entity is liable for federal taxes.  REG-106681-02.  Published April 1, 2004.
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