Informing the Public

Coordination of Extraordinary Disposition and Disqualified Basis Rules

This document contains proposed regulations under sections 245A and 951A of the Internal Revenue Code (the ``Code'') that coordinate the extraordinary disposition rule under section 245A of the Internal Revenue Code (the ``Code'') with the disqualified basis rule under section 951A of the Code. This document also contains proposed regulations under section 6038 of the Code regarding information reporting to facilitate administration of the proposed regulations. The proposed regulations affect corporations that are subject to the extraordinary disposition rule and the disqualified basis rule.