GE not an American corporation?

[Guest Vladimir M]

I have just been told that GE floating rate notes no longer qualify for Section 1042 ESOP rollover, because in IRS's opinion GE does too much non-US business.

I do not doubt the accuracy of this information. However, I would like to know:

1. Is there any literature to support this? An IRS ruling? Anything of the sort?

2. Does then the same restriction apply to GE common stock? GE common stock is NOT considered Qualified Replacement Property for the purpose of Section 1042?

Thank you for your help.

Regards,

Vladimir