Final regulations and removal of temporary regulations.
Category
tax-irs
Sub-agency
IRS
Publication date
2011-05-19
Effective date
2011-05-19
Treasury docket
TD 9526
Abstract
This document contains final regulations under section 367 of the Internal Revenue Code (Code) relating to the treatment of property used to acquire parent stock or securities in certain triangular reorganizations involving foreign corporations. The regulations finalize proposed regulations and withdraw temporary regulations published on May 27, 2008 (TD 9400). The regulations affect corporations that engage in certain triangular reorganizations involving one or more foreign corporations.