other · IRS · Rule · Published 2003-07-02 · Effective 2003-07-02 · 68 FR 39452
Document
Document number
03-16785
Federal Register citation
68 FR 39452
CFR reference
26 CFR 1
Type
Rule
Action
Final regulations.
Category
other
Sub-agency
IRS
Publication date
2003-07-02
Effective date
2003-07-02
Treasury docket
TD 9066
Abstract
This document contains final regulations that provide guidance regarding the application of section 367(e)(2) to certain outbound liquidations. The regulations amend the anti-abuse rule by narrowing the scope of the rule to apply only to outbound transfers to a foreign corporation in a complete liquidation of a domestic corporation in which a principal purpose of the liquidation is the avoidance of U.S. tax. The regulations also clarify the application of the anti-abuse rule.