CFR 26-1.338-5-2013
Internal Revenue. Part1:Income taxes(continued). Section1.338-5:Adjusted grossed-up basis.

Standard No.
CFR 26-1.338-5-2013
Release Date
2013
Published By
US-CFR-file
Latest
CFR 26-1.338-5-2013
Scope
(a) Scope. This section provides rules under section 338(b) to determine the adjusted grossed-up basis (AGUB) for target. AGUB is the amount for which new target is deemed to have pur-chased all of its assets in the deemed purchase under section 338(a)(2). AGUB is allocated among target's assets in accordance with § 1.338–6 to determine the price at which the assets are deemed to have been purchased. When a subsequent increase or decrease with respect to an element of AGUB is re-quired under general principles of tax law, redetermined AGUB is allocated among target's assets in accordance with § 1.338–7.

CFR 26-1.338-5-2013 history

  • 2013 CFR 26-1.338-5-2013 Internal Revenue. Part1:Income taxes(continued). Section1.338-5:Adjusted grossed-up basis.



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