Table of Contents

• Rev. Rul. 2009-5
• T.D. 9442
  • AGENCY:
  • ACTION:
  • SUMMARY:
  • DATES:
  • FOR FURTHER INFORMATION CONTACT:
  • SUPPLEMENTARY INFORMATION:
    • Background
    • Explanation of Provisions
    • Former Regulations Under §1.1502-13(g) (the Former Regulations)
    • Significant Changes Made by the 2007 Proposed Regulations
    • General Comments
    • A. Anti-Abuse Rules
    • B. Deemed Satisfaction and Reissuance for Fair Market Value
    • C. Exceptions and Related Provisions
    • 1. Overlap of Exceptions and Deemed Exchanges under §1.1001-3
    • 2. Exception for Intercompany Taxable Assumption Transactions
    • 3. Intercompany Nonrecognition Exchange Exceptions
    • a. Section 351 Exception
    • b. Scope of Exception under Section 332
    • c. Gain or Loss With Respect to an Intercompany Obligation
    • 4. Outbound Exception for Intercompany Obligations Newly-Issued in a Reorganization
    • 5. Exceptions to the Application of Section 108(e)(4)
    • Special Analyses
  • Adoption of Amendments to the Regulations
    • PART 1—INCOME TAXES
  • Drafting Information