Basis of Stock Received in Type B Reorganizations
"Notice 2009-04 describes methodologies that the IRS is considering publishing as safe harbors to be used in the determination of basis in stock that is acquired in a “B” reorganization or other transferred basis transaction. The methodologies are intended to respond to significant changes in market practice, and the issues raised by those changes, since the publication of Rev. Proc. 81-70, 1981-2 C.B. 729. Also, the notice requests comments on the proposed methodologies and provides that, pending further guidance, taxpayers may rely on the safe harbors set forth in the notice.
Notice 2009-04 will be published in Internal Revenue Bulletin 2009-2 on January 12, 2009."
