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Tax Section Report and Cover Letter 1252
Generally, sections 351(e) and 368(a)(2)(F) deny tax-free treatment for a transaction that qualifies as a section 351 exchange or 368 reorganization where the transaction involves one or more investment companies. This report makes recommendations for the Treasury and IRS to provide guidance that will: ensure the types of transactions Congress was concerned with are subject to recognition, eliminate unintended applications of the provisions, and, provide certainty to taxpayers on significant ambiguities under current law.
Tax Section Report and Letter 1250
The report addresses issues arising out of the enactment of the Hiring Incentives to Restore Employment Act (the "HIRE Act") that relate to the issuance of registered debt after March 18, 2012. This report concerns registered debt following the Hire Act.