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17 July 2024

Final IRC Section 367(b) regulations issued addressing certain cross-border triangular reorganizations and inbound nonrecognition transactions

The IRS and Treasury Department today released final regulations (TD 10004) under IRC Section 367(b) concerning the treatment of property used to acquire parent stock or securities in connection with certain cross-border triangular reorganizations. The final regulations adopt the proposed regulations (see Tax Alert 2023-1683) without substantive changes. A Tax Alert is forthcoming.

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Published by NTD’s Tax Technical Knowledge Services group; Chris DeZinno, legal editor

Document ID: 2024-1391

 

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