• All-Cash D Regulation Amended
  • December 7, 2011 | Author: Jasper L. Cummings
  • Law Firm: Alston & Bird LLP - Durham Office
  • On November 18, 2011, the Treasury filed an amendment to the final regulations published in 2009 that address what is known as the all-cash D reorganization. The amendment clarifies a question about stock basis involving the so-called nominal share, which some had claimed was not clear in the 2009 regulation. The clarification will be viewed as unfavorable to taxpayers, but is not surprising. However, it created yet another ambiguity in the regulation.