Treatment of Gain Recognized With Respect to Stock in Certain Foreign Corporations Upon Distributions
other · IRS · Rule · Published 2012-04-24 · Effective 2012-04-24 · 77 FR 24380
Document
Document number
2012-9760
Federal Register citation
77 FR 24380
CFR reference
26 CFR 1
Type
Rule
Action
Final regulations and removal of temporary regulations.
Category
other
Sub-agency
IRS
Publication date
2012-04-24
Effective date
2012-04-24
Treasury docket
TD 9585
Abstract
This document contains final regulations relating to the characterization of gain recognized with respect to stock in certain foreign corporations upon distributions. The regulations finalize proposed regulations and remove temporary regulations that characterize gain recognized with respect to stock in foreign corporations upon distributions as a deemed dividend in certain situations. The regulations affect certain persons that recognize gain with respect to stock in connection with the receipt of a distribution of property from a foreign corporation.