purchase

(B)The term “purchase” includes any deemed purchase under subsection (a)(2). The acquisition date for a corporation which is deemed purchased under subsection (a)(2) shall be determined under regulations prescribed by the Secretary. (C) (i)Clause (iii) of subparagraph (A) shall not apply to an acquisition of stock from a related corporation if at least 50 percent in value of the stock of such related corporation was acquired by purchase (within the meaning of subparagraphs (A) and (B)). (ii)Clause (i) of subparagraph (A) shall not apply to an acquisition of stock described in clause (i) of this subparagraph if the corporation acquiring such stock— (I)made a qualified stock purchase of stock of the related corporation, and (II)made an election under this section (or is treated under subsection (e) as having made such an election) with respect to such qualified stock purchase. (iii)For purposes of this subparagraph, a corporation is a related corporation if stock owned by such corporation is treated (underother than paragraph (4) thereof) as owned by the corporation acquiring the stock.

Source

26 USC § 338(h)(3)(B)


Scoping language

For purposes of this section
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