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2026-10-16 · Rule · Federal Register document 2026-21253

Non-Applicability of Section 357(c) to Consolidated Groups

Official abstract: This document contains final regulations clarifying that, in the case of certain transfers between members of a consolidated group, a transferee's assumption of certain liabilities will not reduce the transferor's basis in the transferee's stock received in the transfer. These final regulations affect consolidated groups and their members.