Regulations issued on property transfers and stock distributions in cross-border reorganizations
The US Treasury Department and the Internal Revenue Service (IRS) have issued final and temporary regulations (TD 9614) with guidance on property transfers and stock distributions in cross-border reorganizations under sections 367, 1248, and 6038B of the US Internal Revenue Code (IRC).
The new regulations adopt with modifications a portion of proposed regulations (REG-209006-89) issued on …
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