View all text of Part C [§ 1341 - § 1347]
§ 1347. Tax treatment of Conrail public sale
(a) Treatment as new corporation
(1) In general
(2) Allocation among assets
(3) Deemed purchase price
For purposes of this subsection, the deemed purchase price is an amount equal to the gross amount received pursuant to the public sale, multiplied by a fraction—
(A) the numerator of which is 100 percent, and
(B) the denominator of which is the percentage (by value) of the stock of Conrail sold in the public sale.
The amount determined under the preceding sentence shall be adjusted under regulations prescribed by the Secretary for liabilities of Conrail and other relevant items.
(b) No income from cancellation of debt or preferred stock
(c) Disallowance of certain deductions
(d) Waiver of certain employee stock ownership plan provisions
For purposes of determining whether the employee stock ownership plans of Conrail meet the qualifications of sections 401 and 501 of title 26—
(1) the limits of section 415 of such title (relating to limitations on benefits and contributions under qualified plans) shall not apply with respect to interests in stock transferred pursuant to this Act or a law heretofore enacted, and
(2) the 2-year waiting period for withdrawals shall not apply to withdrawals of amounts (or shares) in participants accounts in connection with the public sale.
(e) Definitions
For purposes of this section—
(1) Conrail
(2) Public sale
(3) Secretary
(Pub. L. 99–509, title VIII, § 8021, Oct. 21, 1986, 100 Stat. 1954; Pub. L. 99–514, § 2, Oct. 22, 1986, 100 Stat. 2095.)