19 August 2025 IRS announces intent to propose regulations under IRC Section 897(d) and (e) concerning US real property interests The IRS and Treasury Department on August 19, 2025, announced in Notice 2025-45 their intent to issue proposed regulations under IRC Section 897(d) and (e) that will modify the rules applicable to certain transactions involving the transfer of US real property interests. The forthcoming proposed regulations will apply to inbound asset reorganizations under IRC Section 368(a)(1)(F) that constitute a "covered inbound F reorganization." A Tax Alert is forthcoming.
Document ID: 2025-1712 | ||
