Treasury Regulations (26 C.F.R.)
26 CFR § 1.9002-6 — Acquiring corporation.
Section 5(d) of the Act provides that for purposes of such Act in the case of the acquisition of the assets of a corporation by another corporation in a distribution or transfer described in section 381(a) of the Code the acquiring corporation shall be treated as if it were the distributor or transferor corporation.
Source: official text