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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