Sullivan & CromwellยทTAX

Treasury, IRS Finalize Intragroup 351 Liability Rules; Propose PTC Verification Rules

Final regs effective October 16, 2026 confirm that assuming Section 357(c)(3) liabilities in an intragroup Section 351 transfer does not reduce stock basis; other final and proposed IRS tax rules also issued.

premium-tax-creditsection-351-liabilitiesintragroup-transfersirs-regulationscredit-debit-card-paymentsobba-conforming-regulations
Read the original firm alert โ†’ Thursday, October 22, 2026

Stay ahead

Join the digest.

Each weekday's issue by email, through Substack. Or follow the RSS feed.