New Temp. Reg. Section 1.338-6T: Only One-and-a-Half Traps for the Unwary

In this paper, Jack S. Levin, Martin D. Ginsburg, and Richard A. Wolfe discuss recently issued Temp. Reg. section 1.338-6T, which provides limited relief from the duplicative taxation of the same economic gain or loss that occurs when a code section 338 election is made with respect to a target corporation that has subsidiaries. This article is in PDF format and requires Acrobat Reader.