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