‘Bust-Ups' a Concern Despite Intercompany Gain Rules, IRS Official Says

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IRS tried to offer more flexibility in final rules (T.D. 9515) on the redetermination of intercompany gain in transactions involving consolidated groups, but remains concerned about so-called “bust-up” transactions, a senior IRS official says. The 2008 temporary rules (T.D. 9383) “were issued rather quickly,” Lawrence M. Axelrod, special counsel to the IRS Associate Chief Counsel (Corporate), says at a luncheon sponsored by the D.C. Bar Association Tax Section's Corporation Tax Committee.