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Tax Law

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1977

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Proposed Regs. Under 355 Overhaul Device Test And Single-Business Divisions, John W. Lee Apr 1977

Proposed Regs. Under 355 Overhaul Device Test And Single-Business Divisions, John W. Lee

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Newly issued Proposed Regulations, under Section 355, follow recent decisions allowing horizontal divisions of a single business. In addition, the proposals introduce factors for determining whether a Section 355 transaction is a device for bailing out earnings" Mr. Lee analyzes these and other changes in the Proposed Regulations.