The following article is adapted and reprinted from the M&A Tax Report, Vol. 9, No. 9, April 2001, Panel Publishers, New York, NY.
ASSET ALLOCATION REGS FINALIZED
By Robert W. Wood In mid-February, the IRS published final regulations on determining
the amount realized (and the amount of basis allocated) to each asset transferred
in a deemed or actual asset acquisition. The Treasury Decision (T.D. 8940),
adopts (with modifications) regulations that were proposed in August of
1999 (REG-107069-97), and the temporary regulations that were published
in January of 2000 (T.D. 8858).
Looking through regulations on purchase price allocations may not
be everyone's idea of an exciting evening by the fire. Still, these final
regulations are quite important. If one doesn't want to read them cover
to cover, there are at least a handful of provisions in the final regulations
that are truly important to note. One of them, certainly, is the anti-abuse
rule. The proposed regulations had set out an anti-abuse rule that seemed
extremely broad in scope. It basically could apply wherever there was a
transfer of assets from their original location to more than an insignificant
extent. This "to more than an insignificant extent" phrase was changed
in the final regulations to the much more flexible "primarily." The idea,
says the Service, is to clarify that some continuing use in the original
location of an asset transferred to or from the target is permissible.
Another change concerns purchasers acquire stock of a subsidiary
member of a consolidated group. It has been argued that such a purchaser
could, after acquiring the stock of the target, cause the target to sell
all of its assets to another person later on the closing date (in other
words, later during the same day), and then make a unilateral Section 338(g)
election. Perhaps this is just arguing about how many angels can dance
on the head of a pin. Still, it seemed like a significant issue.
The final regulations, therefore, provide a new rule that requires
the application of a "next day rule" in a Section 338 context. When the
target engages in a transaction outside the ordinary course of business
on the acquisition date after the event resulting in a qualified stock
purchase, the next day rule applies. Single Definition of Purchase
The final regulations provide a single definition of the term "purchase,"
applying to both targets and target affiliates. Under the new definition,
stock in a target or target affiliate may be considered if, under general
principles of tax law, the purchasing corporation owns stock of the target
or target affiliate meeting the requirements of Section 1504(a)(2), notwithstanding
that no amount may be paid for or allocated to the stock. Transactions After Qualified Stock Purchases
Since 1995, the regulations under Section 338 have provided special
rules that apply to certain transfers of target assets following a qualified
stock purchase of a target's stock if a Section 338 election is not made
for the target. These provisions modify the normal operation of the "continuity
of interest" requirement under Section 368, and the interpretation of the
term "shareholder" for purposes of Section 368(a)(1)(D).
The idea of these rules was to effectuate Congressional intent in
replacing now-repealed Section 334(b)(2) with Section 338. Remember the
very simple and straightforward Section 334(b)(2) liquidation — that Congress
thought would be so much simpler by enacting Section 338? Every so often,
I long for the old and simple two-year liquidation rule that was replaced
by the behemoth of Section 338!. The reason for the special rules governing
transactions after qualified stock purchases was the notion that the deemed
sale results provided by Section 338 should not be available through transactions
with the purchasing group after the acquisition (these rules are located
in Section 1.338-3(d) of the regulations).
The 1995 amendments did not provide any special rule to modify the
application of these rules for C reorganizations. However, the newly-published
final regulations indicate that the considerations justifying the modified
application of the continuity of interest rule (and the shareholder definition
for D reorganizations) also justify an analogous modification of the "solely
for voting stock" requirement for post-acquisition C reorganizations.
Thus, the final regulations provide that consideration other than
voting stock which is issued in connection with a qualified stock purchase
will be ignored in determining whether a subsequent transfer of assets
by the target corporation to a member of its new affiliate group satisfies
the "solely for voting stock" requirement of a C reorganization. (For this
rule, see Reg. §1.338-3(d)(4).) Treatment of Liabilities
The proposed regulations had eliminated the prior distinction between
"modified aggregate deemed sale price" (sometimes called "MADSP") on the
one hand, and "aggregate deemed sale price" (or "ADSP") on the other. This
distinction was apparently based on the notion that the new target generally
will not bear the tax liability of the deemed sale where a Section 338(h)(10)
election has been made. On the other hand, the new target generally will
bear the tax liability where a regular Section 338 election has been made.
The Preamble to the new final regulations indicates that these generalizations
were not universally correct. And, there was a fair amount of commentary
on this topic.
Instead of providing more specific guidance which the Service now
apparently believes would be inconsistent with the overall philosophy of
deferring to general tax principles governing actual transactions, the
final regulations simplify the discussion of liabilities. Except for the
fact that the new target remains liable for the old target's tax liabilities,
and that a buyer's assumption of a seller's income tax liability with respect
to the sale causes the consideration to "gross up" the liability, a tax
liability is treated like any other type of liability. The status of any
particular type of tax liability as a liability includable in either ADSP
or adjusted grossed-up basis should be determined under general principles.
See Reg. §1.338-1(b)(3)(i). Various other topics are also detailed in the final regulations,
including:
a simplification of the discussion of liabilities; the sentence about valuing goodwill and going concern value from Prop.
Reg. §1.338-6(a)(2)(iii) has been deleted; the scope of Class II assets has been modified; new provision states that Class III assets consist of assets that the
taxpayer marks to market at least annually, and debt instruments including
receivables; rules regarding special treatment for changes in aggregate deemed sale
price or adjusted grossed-up basis occurring before the close of the new
target's first tax year have been removed; and a statement now appears in Reg. §1.1361-1(i)(2)(v) that the payment
of varying amounts to S corporation shareholders in a transaction for which
a Section 338(h)(10) election is made will not cause the S corporation
to violate the single class of stock requirement, provided that the varying
amounts are negotiated at arms-length with the purchaser. For further details of these regulations, see 66 Fed. Reg. 9925-9957,
T.D. 8940, Tax Analysts Doc. No. 2001-4434, 2001 TNT 30-5.
Asset Allocation Regs Finalized, Vol. 9, No. 9, M&A Tax
Report (April 2001), p. 1.