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Mentioned 1× · first seen 02-nov-2026 · last seen 02-nov-2026

Section 357© Non-Applicability to Consolidated Groups

Current understanding

To be populated as evidence accumulates.

Evidence log

  • 2026-10-16 — Non-Applicability of Section 357© to Consolidated Groups: Final IRS rule clarifies that Section 357© does not apply to intra-group asset transfers in a consolidated group — a transferor member no longer must reduce its basis in stock received by the amount of liabilities assumed by the transferee member. (novelty: 2)

Open questions

Related

Contributing findings

Executive final rule
Non-Applicability of Section 357(c) to Consolidated Groups
16-oct-2026 novelty 2 per-area 2 introduces

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