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United States | Notice 2024-16 provides that Section 961(c) basis of acquired CFCs carries over to domestic acquiring corporations in certain covered inbound transactions

|Tax Alerts, National/Federal Taxation, L ...|United States
United States

  • The Notice defines a "covered inbound transaction" to include IRC Section 332 liquidations and certain asset reorganizations described in IRC Section 368(a)(1).
  • Stock ownership requirements and other limitations in the Notice disqualify specific types of transactions from qualifying as covered inbound transactions.
  • Taxpayers may rely on this guidance for transactions completed before the issuance of forthcoming proposed regulations, subject to certain conditions.
 

In Notice 2024-16 (Notice), i…

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