Page:United States Statutes at Large Volume 100 Part 3.djvu/474

 100 STAT. 2282

PUBLIC LAW 99-514—OCT. 22, 1986

(1) IN GENERAL.—No gain or loss shall be recognized under the Internal Revenue Code of 1986 to a corporation (hereinafter in this subsection referred to as "parent") on a qualified distribution. (2) QUALIFIED DISTRIBUTION DEFINED.—For purposes of paragraph (D— (A) IN GENERAL.—The term "qualified distribution" means a distribution— (i) by parent of all of the stock of a qualified subsidiary in exchange for stock of parent which was acquired for purposes of such exchange pursuant to a tender offer dated February 16, 1982, and (ii) pursuant to a contract dated February 13, 1982, and (iii) which was made not more than 60 days after the board of directors of parent recommended rejection of •''• ' ' an unsolicited tender offer to obtain control of parent. (B) QUALIFIED SUBSIDIARY.—The term "qualified subsidiary" means a corporation created or organized under the laws of Delaware on September 7, 1976, all of the stock of which was owned by parent immediately before the qualified distribution. SEC. 634. STUDY OF CORPORATE PROVISIONS.

The Secretary of the Treasury or his delegate shall conduct a study of proposals to reform the provisions of subchapter C of chapter 1 of the Internal Revenue Code of 1986. Not later than January 1, 1988, the Secretary shall submit to the Committee on Ways and Means of the House of Representatives and the Committee on Finance of the Senate a report on the study conducted under this section (together with such recommendations as he may deem advisable).

Subtitle E—Other Corporate Provisions SEC. 641. SPECIAL ALLOCATION RULES FOR CERTAIN ASSET ACQUISITIONS.

(a) IN GENERAL.—Part IV of subchapter O of chapter 1 (relating to special rules for determining basis) is amended by redesignating section 1060 as section 1061 and by inserting after section 1059 the following new section: "SEC. 1060. SPECIAL ALLOCATION RULES FOR CERTAIN ASSET ACQUISITIONS.

"(a) GENERAL RULE.—In the case of any applicable asset acquisition, for purposes of determining both— ^, "(1) the transferee's basis in such assets, and ' "(2) the gain or loss of the transferor with respect to such acquisition, the consideration received for such assets shall be allocated among such assets acquired in such acquisition in the same manner as amounts are allocated to assets under section 338(bM5). "(b) LN'FORMATION REQUIRED TO BE FURNISHED TO SECRETARY.—

Under regulations, the transferor and transferee in an applicable asset acquisition shall, at such times and in such manner as may be

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