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Expert Analysis

IRS And Treasury Look To Ease Burden Of Fractions Rule

By Jonathan Talansky, King & Spalding LLP (December 14, 2016, 4:10 PM EST) -- On Nov. 22, the Internal Revenue Service and the Treasury Department issued proposed regulations (REG-136978-12) under the "fractions rule" of Section 514(c)(9)(E) of the Internal Revenue Code of 1986, as amended[1]. The proposed regulations attempt to address many of the problems that have dogged the fractions rule, as interpreted in the existing regulations, since its enactment thirty years ago....

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