Final IRC Section 367(b) regulations address certain cross-border triangular reorganizations and inbound nonrecognition transactions
|Tax Alerts, Information Reporting, Infor ...|United States
The final regulations adopt the October 2023 proposed regulations without any substantive changes.
As it relates to cross-border triangular reorganizations, the final regulations adopt the modifications to IRC Section 367(b) regulations proposed in Notice 2014-32, as modified by Notice 2016-73.
As it relates to the inbound nonrecognition transactions, the final regulations provide a taxpayer-friendly modification to the guidance in Notice 2016-73 by limiting the scope of the "excess asset basis" r…
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