Treasury has released its report detailing actions that it plans to take to "reduce the burden" of eight tax regulations identified in July 2017 (see Tax Alert 2017-1086) under an executive order. In the report, Treasury announces plans to:

— Retain the distribution rules in the Section 385 regulations on treatment of certain interests in corporations as stock or indebtedness (T.D. 9790; see Tax Alert 2016-1776), pending tax reform
— Replace the current documentation rules in the Section 385 regulations with "streamlined documentation rules"
— Consider substantial revisions to the final Section 987 regulations (T.D. 9794; see also Tax Alerts 2017-55 and 2016-2117)
— Consider substantial revisions to the final regulations under Section 367 eliminating the foreign goodwill exception and limiting the Section 367(a)(3) active trade or business exception to certain tangible property and financial assets (T.D. 9803; see also Tax Alert 2016-2193)
— Consider substantial revisions to the temporary Section 337(d) regulations on certain property transfers to regulated investment companies and real estate investment trusts (T.D. 9770, see also Tax Alert 2016-1083)
— Partially revoke the temporary Section 752 regulations on liabilities recognized as recourse partnership liabilities (T.D. 9788; see also Tax Alert 2016-1715)
— Withdraw proposed regulations under Section 2704 on restrictions on liquidating an interest for estate, gift and generation-skipping transfer taxes (REG-163113-02; see also Tax Alert 2016-1345)
— Withdraw proposed regulations under Section 103 on the definition of a political subdivision (REG-129067-15)
— Partially revoke the final regulations under Section 7602 addressing the participation in a summons interview of a person with whom the IRS has contracted for services, such as an economist, engineer, consultant or attorney (T.D. 9778)

Tax Alerts are forthcoming.