Opportunity

Federal Register #REG-134016-15

Treasury and IRS Partially Withdraw Proposed Section 355 Regulations

Buyer

Treasury Department, Internal Revenue Service

Posted

October 21, 2026

Identifier

REG-134016-15

The Department of the Treasury and the Internal Revenue Service (IRS) partially withdraw proposed regulations under Section 355. - Government entities: Department of the Treasury and IRS; no sub-agency or office is specified. - Action: Withdraws the proposed per se device test and related anti-abuse rules concerning the device prohibition and active trade or business requirement for certain tax-free distributions of controlled corporation stock, or stock and securities. - Affected parties: Corporations, shareholders, and security holders. - Procurement: This is a regulatory action, not a procurement opportunity. No products, services, quantities, part numbers, OEMs, or vendors are identified.

Description

The document partially withdraws proposed regulations concerning the device prohibition and active trade or business requirement for tax-free distributions of controlled corporation stock or stock and securities. It withdraws proposed rules for a per se device test and related anti-abuse rules. The regulations affect corporations and their shareholders and security holders. The withdrawal is effective October 21, 2026; the remaining rules and judicial doctrines are not affected.

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