CFR 26-1.336-3-2013 Internal Revenue. Part1:Income taxes(continued). Section1.336-3:Aggregate deemed asset disposition price; various aspects of taxation of the deemed asset disposition.
(a) Scope. This section provides rules under section 336(e) to determine the aggregate deemed asset disposition price (ADADP) for Target. ADADP is the amount for which old Target is deemed to have sold all of its assets in the deemed asset disposition. ADADP is allocated among Target's assets in the same manner as the aggregate deemed sale price (ADSP) is allocated under § 1.338–6 to determine the amount for which each asset is deemed to have been sold. If a subsequent increase or decrease is required under general prin-ciples of tax law with respect to an ele-ment of ADADP, the redetermined ADADP is allocated among Target's as-sets in the same manner as redeter-mined ADSP is allocated under § 1.338– 7.
CFR 26-1.336-3-2013 history
2013CFR 26-1.336-3-2013 Internal Revenue. Part1:Income taxes(continued). Section1.336-3:Aggregate deemed asset disposition price; various aspects of taxation of the deemed asset disposition.