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TABLE OF CONTENTS
FINAL TEMPORARY AND PROPOSED REGULATIONS
2 other sections not shown
acquisition date adjusted basis ADSP AGUB allocated attributable capital loss cash computed controlled corporation controlled foreign corporation corporation's date of distribution December 31 deemed asset sale deemed sale deficit described in paragraph described in section determined disposition distributing corporation distribution or transfer domestic corporation earnings and profits fair market value FC stock filed following examples foreign income taxes Foreign taxes gain or loss graph immediately intangible property interest Internal Revenue Code January June 30 liabilities liquidation merger method of accounting old target operating loss outstanding stock paragraph b)(1 percent poration preferred stock purchasing corporation purposes of section pursuant qualified stock purchase quired recognize gain redeemed redemption section 1248 amount section 338 election section applies selling shareholder stock of Corporation stock or securities subparagraph taken into account target affiliate target corporation taxable income tion trade or business transaction transferee foreign corporation transferor corporation treated U.S. person