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SUBCHAPTER C (SUPPLEMENTAL STUDY) 1 (MEMORANDUM 1, May 8-9, 1987)

handle is hein.ali/aliftp0343 and id is 1 raw text is: AMERICAN LAW INSTITUTUTE
Federal Income Tax Project
Subchapter C                            //  n -e
Consultants' Meeting
May 8-9, 1987
10:00 am in the John Chipman Gray Room
Harvard Law School, Cambridge, Massachusetts
This is later and less complete than I had hoped or planned.
But we will have lots to discuss. I look forward to seeing you
all again.
Our primary task is -co review our prior proposals concerning
taxation of corporate transactions, in light of subsequent
legislation and other developments, and to recommend appropriate
revisions and additions. I believe it will be useful to follow
the division of subject matter in the 1982 volume, taking up
first the Acquisition Proposals and then the Reporter's Proposals
on Distributions. I propose that we spend a day on each.
The Acquisition Proposals were adopted by the Institute and
have been the subject of further examination by various groups,
most importantly the staff of the Senate Finance Committee, which
ultimately produced its own set of proposals (hereinafter the
Green Book') covering much of the same ground. Some aspects of
the Acquisition Proposals have been enacted: an explicitly
elective means of securing cost basis treatment in the case of a
corporate stock acquisition, in § 338; a new set of limitations
on loss carryovers in corporate acquisitions, in § 382; and

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