The fourth time's a charm: new temporary section 355(e) regulations provide helpful guidance to taxpayers.(anti-Morris Trust provision)(Internal Revenue Code) Tax Executive | May 1, 2002| | COPYRIGHT 2002 Tax Executives Institute, Inc. This material is published under license from the publisher through the Gale Group, Farmington Hills, Michigan.  All inquiries regarding rights should be directed to the Gale Group. (Hide copyright information) Copyright

I. Background

In 1997, Congress enacted the Taxpayer Relief Act of 1997 (TRA 1997), (1) which added section 355(e) to the Internal Revenue Code. (2) Under section 355(e), the so-called anti-Morris Trust provision, (3) a distributing corporation will recognize gain if one or more persons acquire, directly or indirectly, 50 percent or more of the stock (measured by vote or value) of the distributing or any controlled corporation as "part of a plan (or series of related transactions)" (hereinafter referred to as a "plan") that was in place at the time of the ...

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