U.S. IRS Issues Notice on Proposed Regulations on F Reorganizations Involving Transfer of U.S. Real Property Interests

The U.S. IRS has issued Notice 2025-45 on plans to issue proposed regulations modifying how Sections 897(d) and (e) apply to certain inbound asset reorganizations under Section 368(a)(1)(F) (F reorganizations), specifically those involving the transfer of U.S. real property interests.

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Notice 2025-45: certain transactions involving the transfer of United States real property interests

Issue Number: Notice-2025-45

Notice 2025-45 announces that the Department of the Treasury and the …