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United States | Proposed Regulations would amend IRC Section 367(b) regulations applying to certain cross-border triangular reorganizations and inbound nonrecognition transactions

|Tax Alerts, Legislation & Policy|United States
United States

  • As it relates to cross-border triangular reorganizations, the proposed regulations would 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 proposed regulations introduce a taxpayer friendly modification to the guidance described in Notice 2016-73 by limiting the scope of …

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