Pre-exchange earnings and profits.

(2) Pre-exchange earnings and profits. All earnings and profits (or deficits) accumulated by a foreign corporation before the reorganization and attributable to a share (or block) of stock for purposes of section 1248 are attributable to the divided portion of stock with the basis and holding period of that share (or block). See 1.367(b)-4(d).

Source

26 CFR § 1.367(b)-13


Scoping language

None
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