Reorganizations Under Section 368(a)(1)(F); Section 367(a) and Certain Reorganizations Under Section 368(a)(1)(F)
other · IRS · Rule · Published 2015-09-21 · Effective 2015-09-21 · 80 FR 56904
Document
Document number
2015-23603
Federal Register citation
80 FR 56904
CFR reference
26 CFR 1
Type
Rule
Action
Final regulations and removal of temporary regulations.
Category
other
Sub-agency
IRS
Publication date
2015-09-21
Effective date
2015-09-21
Treasury docket
TD 9739
Abstract
This document contains final regulations that provide guidance regarding the qualification of a transaction as a corporate reorganization under section 368(a)(1)(F) by virtue of being a mere change of identity, form, or place of organization of one corporation (F reorganization). This document also contains final regulations relating to F reorganizations in which the transferor corporation is a domestic corporation and the acquiring corporation is a foreign corporation (an outbound F reorganization). These regulations will affect corporations engaging in transactions that could qualify as F reorganizations (including outbound F reorganizations) and their shareholders.