- Tax-free reorganizations under IRC § 381(a)(2).
- Issuances of stock subject to IRC § 1032.
- Redemptions of stock.
- Deemed acquisitions of stock as a result of the issuance of a right to acquire stock.
- Transactions identified in the Internal Revenue Bulletin.
- Dispositions of stock by first tier and higher tier entities.
See Treas. Reg. § 1.382-2T(j)(2)(iii).